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?
Can we surcharge our own customers at certain ATMs that we own (that are in low volume areas), provided that we have the appropriate disclosures at the ATM? In the initial disclosures, we disclose that we charge an ATM Transaction fee only for ATMs not owned by us.
The Federal Reserve Board staff has held constant and issued a proposed update to Regulation Z's Official Staff Commentary in time for the holiday mail.
What are the Reg E disclosure requirements regarding a merchant's use of electronic collection for checks presented for payment?
We recently implemented John Floyd's Overdraft Privilege Program and we understand that some examiners are requiring banks to carry each account that has ODP on the Call Report as a "Unfunded Committment". We thought that since these limits were non-contractual that they would not be considered "Unfunded Commitments".
The question always comes up for the early TIL as to how to count the three days. Everything says "within three days". Do you count the day of signing? Can you clarify?
We provide Reg. E disclosures for banks. Recently one of our banks was examined by the FDIC and cited because of the MasterCard debit card liability limits. The bank uses the MasterMoney debit card and the zero liability language provided by MasterCard was included in their Reg. E disclosure. However, the FDIC says that the conditions required to be met for zero liability violate Reg. E because they are more restrictive than the regulation. We have, of course, contacted MasterCard as well as the Federal Reserve Board regarding this issue.
The Consumer Protection in Sales of Insurance regulation (343.40(d)) indicates that advertisements and other promotional material for insurance products or annuities must include the insurance disclosures. We include promotional information about insurance products on our web site and if customers are interested, they would e-mail or call us for more information. Prior to selling the insurance, we provide the insurance disclosure in writing and obtain the customer's consent. Section 343.40(c)(4) describes providing disclosures in an electronic format and requires that a consumer affirmatively consents to receiving the disclosures electronically. Would the electronic consent requirement apply when we are only posting promotional material on the web site ?
When you have a loan administrative fee or a loan fee how do you disclose the APR? The fee is not included in with the amount financed, but is included in with the finance charge and it does raise the APR. For example a loan of $4,000.00 at a rate of 6.90%, $20.00 loan administrative fee, has an APR of 7.1596%. A loan at $5,000.00 at a rate of 6.90%, $20.00 loan fee, has an APR of 7.1061%. If you are running a loan special what APR do you use if they are different?