If a customer places an order online, but never receives their merchandise, do we have to investigate?
Since MasterCard’s Zero Liability covers ATM withdrawals and PIN transactions. It is even worth investigating Reg E claims since we are always on the hook?
What could happen is we discontinue safe deposit services?
We are rolling out a new rewards program. For members who maintain multiple accounts with direct deposit and have an average balance of at least $XX,XXX, we’re going to rebate X% of each debit card purchase, up to $100 per year. I was reading some compliance discussions that noted if the credit/rebate is tied to a service instead of just opening and maintaining an account, then it would not be considered a bonus or need to be reported on a 1099-INT. In this case, the accountholder would first need to qualify for a certain level on our rewards program based on their products and balance. However, to receive the rebate, they would need to use their debit card to receive the rebate reward up to $50. We are leaning towards the rebates not being a bonus or reported on a 1099-INT as payment is triggered on the use of their debit card, not solely on opening or maintaining an account. Thoughts?
I received the following question from one of our Lenders and I am having a hard time tracking down an answer: "First lets define a Transactional Broker. In this context, a transactional broker is an agent that is not licensed. The agent will usually work under a supervisor. A transactional broker may be listed on a purchase contract, but they will be identified a Limited Agent (or similar language, sample contract attached). Transactional brokers are also called Statutory Brokers (often in WY) and occasionally Intermediary. It is important to note that a licensed agent can work in a "Limited" capacity, but a non-licensed agent (Transactional Broker) can never represent a buyer or seller. That means, not all contracts with limited agents are "Transactional Brokers." Assumption 1: When the agent is licensed, even when they are shown as working in a limited capacity, then their contact information is to be shown on page 5 of the closing disclosure (CD). Is this a correct understanding? Do divisions have discretion on this point? Can they leave the contact information off in order to match the Seller CD produced by title? This is common practice by title companies in this area. Next question, what is best practice when the limited agent is not licensed? Do we show non-licensed agents (Transitional Brokers) on the CD, without a license number, or do we leave their name off the CD? Last point of clarification, it is our understanding that discrepancies in the contact information section of the CD (page 5) are to be included in the post closing seller CD Review process outlined in the Seller Obligated Job Aid. Please confirm."