Our new marketing director believes we have to be on Facebook, Twitter and other social media, and believes having employees writing and making the posts will make us more transparent and friendly to our customers. What risks do we face with all-employee access?
Do employees outside of Operations really need to understand the ACH Network?
How long is the ODFI responsible for unauthorized consumer debits?
We only process loan payments for our customers, where our customer can make loan payments using their account at another bank. Are we an ODFI or RDFI?
Aren’t ODFIs responsible for everything in the ACH Network?
Aren’t all rules for ACH transactions covered in the Nacha Operating Rules and Guidelines?
We mailed the borrower’s Loan Estimate and they emailed us that it was received, and they want to proceed with the loan. Can we act on this emailed notice?
Can we bank hemp growers? Is it marijuana?
What is your opinion of offering a checking account that offers add-on third party benefits as a feature of the account? Customers are only able to obtain the add-on services if they buy the account and pay the service charge disclosed for this product.
The loan estimate must be delivered or placed in the mail not later than the third business day (general rule) after receipt of the consumer's application. As long as you can document that the email was sent not later than the third business day you will be fine.