07/01/2003
06/24/2003
The Federal Reserve Board has issued a final amendment effective July 22 to Regulation CC that updates routing numbers for Federal Reserve and Federal Home Loan Banks.
06/16/2003
We are getting ready to launch a promotional mortgage rate product if the borrower opens and maintains a DDA with a specific threshold balance. Is there specific language to disclose this promotional product to the borrower and then secondly, what special considerations would need to be given if a mailing or other form of marketing is conducted?
06/16/2003
I was working on a general ad for our community bank and I wanted to do a checklist of all of the services that we offer. If I list our checking options and then include that we offer regarding investment and insurance services what disclosures do I need to include? Should the FDIC disclosure be included since I am listing checking options?
06/09/2003
Our President wants to implement a different type of early withdrawal penalty structure. For example, for CDs of 1 year or less, the penalty assessed would be 3% of the amount withdrawn. For CDs of maturity of greater than 1 year, the penalty assessed would be 6% of the amount withdrawn. If we are able to get our data processor to support this and our documents and disclosures to correctly disclose this, do the regulations allow us to use such an early withdrawal penalty structure?
06/02/2003
Can we include on our bank statements a message that simply states "See enclosed insert for information regarding our Investment Products"? The statement does have Member FDIC marked on it.
04/07/2003
I want to advertise IRAs which can be either a nondeposit investment product or a FDIC insured deposit product. What type of disclosure is needed? If you put FDIC on the ad, it doesn't cover investment products?
04/07/2003
I have a question that involves point of sale transactions (POS) on a statement savings or NOW checking account; can we charge a fee for the following scenario?A customer has a balance in a statement savings or checking account of $100.00. They use their ATM/Master Card Debit to make a purchase of $100.00. The same day they make a withdrawal over the counter for $50.00, the preauthorized debit comes through the next day and the account is overdrawn by $50.00.The questions again are: <ol><li>Can we charge an NSF fee for the point of sale transaction which has now put their account in the negative? <li>We cannot return a POS once it has been pre-authorized, right? <li>And, what disclosure must we provide to the existing customers as well as new ones if we are allowed to charge a fee? <li>What is the maximum fee we can charge, if any?</ol>
03/24/2003
Currently, if a customer comes into the bank to open a checking accountt but Chexsystems says they had a previous account closed by another bank, we open a savings account for this customer with no ATM card. We have seen a problems with this as the customer will then withdraw the funds or leave a few dollars in the account the next day. We are considering putting a 5 day hold on any new customer savings account. Is there any Reg that prohibits this practice?
01/16/2003