We had a member inform us it was the "law" that we supply privacy notices in braille. We do supply privacy notices to ALL members on the Internet, in our statement once a year and to All new members when an account is opened. Must we now ensure that we have a privacy statement for our disabled members, e.g., deaf, blind, etc.?
In a recent speech, Acting Comptroller of the Currency Julie Williams said, "Disclosures are the heart of the consumer protection system, but the system is on the verge of breaking down and fundame
We have tier level accounts. We would like to distinguish our funds availability by account tier. Does this require separate disclosures?
We considering offering a bonus gift card worth $100 to "switch banking relationship." Even though it may not be tied to a trigger APY for example, we need to disclose simply what it is and what they have to do to get it, right?
Even though savings, time deposits and money markets are not regulated by Regulation CC, can you apply the same holds to the accounts as you would transactions accounts?
Like most banks, we offer customers the ability to tie their savings account to a checking account to help cover NSFs. However, because it is a pre-authorized transfer, it counts against the excessive withdrawal limits savings accounts are subject to. I've had someone suggest changing the status of our savings accounts to a NOW account. Have you ever seen this done?
Does notification of Check 21 have to go out to all customers, including savings and time account holders, or just to transaction account customers?
Our bank is planning on celebrating our five year anniversary. We would like to give away a $5,000 five year 5% certificate of deposit. We would also like to make this 5% five year CD product available to the public for that week only. What disclosures are necessary in our advertisment? Since this giveaway would be available to the public are there any advertising disclosures necessary regarding the giveaway.
Are there any dollar amount limits on promotional or gifted items given to bank clients from the bank? Who would these be reported to and is there a difference if it is an existing customer or a new one?
We are in the process of putting together a new fee schedule where we have increased some of our fees. When sending the new fee schedule out, must we list the old and new fees on the disclosure?