03/17/2024
How do you deal with a vendor point of contact who is not providing you with the documentation that you are requesting?
03/17/2024
Do we really need to conduct due diligence on all of our 3rd party vendors, including fintechs? I can understand the ones that appear to be riskier, but there are some that are very well-known in the industry and are very well respected. Wouldn’t the regulators just see the same thing in our file as they did the last bank they just left?
03/17/2024
At what level should policy and procedures for handling garnishments and subpoenas be approved?
03/17/2024
We have a Director who (together with his wife) shares ownership of a law firm. I just learned that we booked a $525,000 loan for that law firm. The loan has a rate and terms comparable to other loans. Is this a problem for Reg O?
03/17/2024
I have heard that business accounts do not fall under Reg E. How does this apply to internet banking and what about a business account that is a sole proprietorship?
03/10/2024
Why should we ask bank counsel to review our policies and procedures on handling garnishments and summonses? Doesn’t that just add costs to the effort?
03/10/2024
If a consumer purchased tires and later claimed they were defective and they filed a Reg E claim, but refused to go back to the merchant, can we deny his claim?
03/10/2024
Does there always have to be a written authorization for an ACH transaction affecting a consumer’s account?
03/10/2024
When we do engage new vendor, especially fintechs for new digital banking products (like BNPL or Buy Now Pay Later), what type of access to records should we expect to have to be able to monitor for compliance?
03/03/2024
Why can't we hold customers liable for carrying their PIN with their card?