05/17/2004
We want to promote our bank when we make home loans by placing a yard sign on the property, at least temporarily. It will have the bank's logo and say "Helping the community grow." What needs to be on the sign?
05/03/2004
If a Realtor were to describe a property, a single family residence, and also state "Special Financing 5% Down, No PMI, $1612.06/Mo." would the requirement to disclose an APR be triggered? If so, what would be the violation for not doing so? Incidentally, this is an advertisement on a $429,900 listing.
04/19/2004
We are preparing a new signature card. What is required by law to be disclosed on the card?
04/05/2004
Our bank is going to be observing our 30 year anniversary soon and we are planning on having drawings for gifts(meals, DVD players, weekend trips). We are not limiting this to customers only; this will be for anyone who registers. We will also present gifts of appreciation to 100 customers who opened an account with us 30 years ago. The drawings and gifts are not connected to any bank product. Will this be an issue in the advertising regulations?
03/15/2004
What are the REQUIRED disclosures that are to be included with monthly customer account statements?
12/15/2003
Our bank shares nonpublic personal information with an unaffiliated third party with whom we have a joint marketing arrangement for marketing credit card accounts. Under the agreement we are required to provide them in an electronic format the names, addresses, telephone numbers and social security numbers of our existing customers for the purpose of allowing them to solicit our customer for credit card accounts. Are we allowed to disclose telephone numbers and particularly social security numbers without providing our customers the opportunity to opt out? Our initial and annual disclosures do contain the required verbiage that we may disclose all of the information we collect to companies that perform marketing services on our behalf or with whom we have joint marketing agreements?
12/15/2003
We are in the process of simplifying our deposit products and changing some of our current fees. Does "Change In Terms" have to be stated on the letter notifying the customer of the changes? Notification is being done with a separate mailing (along with the Privacy Notice). One account is being rolled into another and it has been "*" in the Service Fee Brochure. (The customer mailing will go out with a new Service Fee Brochure.) Does this type of change need to be more obvious or can we just use a * refering them to the bottom of the disclosure. When changing fees, do we have to list the old fee and the new fee or can we just list all of the fees in one leaflet and not reflect a changed amount?
11/01/2003
The banking industry has been so caught up with 326, 314, and CIP of the PATRIOT Act that some really big legislation almost managed to get by without a whole lot of press or notice.
09/15/2003
A customer has a Savings account that is set to receive an annual statement. The customer signs up for the Bank's Internet Banking product that allows transfers between the customer's savings and checking account. Question: If a transfer never occurs between the savings and checking account, does the bank have to send a quarterly statement or can the bank continue to send an annual statement?
08/11/2003
Is there a daily limit on the number of NSF fees we can charge against a customer's account? For example, if they have 10 NSF checks in one day, can we charge 10 fees?