During a recent compliance forum I understood the consultant to say that the 7 day notice of withdrawal language needed to be a part of the TISA disclosure – even if it is part of the terms and conditions disclosure. It is not at our bank. I spoke with a bank manager that has a background in compliance but has been out of the deposit compliance loop for several years. He says that as long as it was in our T&C then we should be fine. I can’t get what the consultant said out of my head – can you help? Is there a citation that addresses this in Reg DD or Reg D? Maybe I misunderstood?
Our bank has limited the number of overdrafts an employee may have in a rolling 11 month period. Management now would like to treat employee like other bank depositors and eliminate the limit. Are there any compliance concerns with this action? My initial comment was that employees of a bank should be held to a higher standard as the general public is entrusting their funds in the integrity of the bank's staff. Thoughts?
Is there anywhere to locate Successor In Interest confirmation letter templates or examples?
Do we have to change our Savings Deposits?
Did the CFPB issue a statement about enforcement of prohibitions on the use of estimates in remittance transfer disclosures in light of the COVID-19 pandemic?