04/23/2023
When reading the Consumer Financial Protection Circular 2022-06, we are trying to understand if banks are not allowed to charge an overdraft fee on a transaction that was authorized positive and settled negative, regardless if they had OD privilege or not? In the Circular 2022-06, it states that overdraft fees can be deemed unfair acts or practices even when the financial institution complies with federal regulations including Regs Z and E.
04/09/2023
When reporting an overdrafted account to Chex Systems , if it is a sole owner is an LLC business account do we report it with the TIN or the owners Social Security Number?
02/12/2023
We have changed our verbiage on our fee schedule to match the verbiage on our important terms and conditions regarding representments of checks. I was going to send out a letter with the updated fee schedule, but due to cost I would like to include the separate letter in the statement envelope. Does anyone see an issue with this?
01/01/2023
Were there any new developments affecting ACH operations?
12/25/2022
What changes are coming for payments processing?
12/18/2022
When will FinCEN raise the threshold for CTR reporting?
12/11/2022
Have there been any significant BSA/AML penalties imposed on banks?
12/11/2022
In light of the recent CFPB Consent Order against Regions Bank for charging Authorized-Positive OD fees, help me understand these were transactions that were not related to Reg E Opt In status? In other words, because these transactions had sufficient available balance it would not have mattered what there Reg E status was. Is that a true statement?
12/04/2022
What’s the latest word on overdrafts and overdraft fees?
06/21/2020
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?