Most Popular Operations Content
APY Disclosure Requirement for a Bonus
12/01/2019
We are advertising a $125 bonus that will be paid when a customer completes a few requirements, including opening 1 of 3 various non-interest and interest-bearing checking accounts, signing up for a direct deposit, and using our mobile banking app. I wasn't planning to disclose an interest rate or APY to avoid the additional disclosures caused by the trigger term. However, when disclosing a bonus, the APY appears to be a requirement. I wanted to verify that we have to disclose the APY (using the term annual percentage yield) and the additional disclosures caused by this trigger term if we are disclosing a bonus. Or, does the APY disclosure requirement for a bonus not apply if we were not planning to disclose the interest rate or APY? Also, are we required to use the word "bonus" in our ad?
Mobile deposits and Reg CC
11/24/2019
Have mobile deposits become subject to Regulation CC yet?.
CRA options for small banks
11/24/2019
We are a small bank for CRA and do not collect gross annual revenue for some of our small business lending products. What is the best thing to do for CRA audits and exams to analyze our data?
Reg Visa 120 Days Rule for Disputes
11/24/2019
We were notified by a customer on September 27, 2019 that there are 72 POS debits totaling $1,373.01 from PlayStation on her account that she did not authorize. Since Visa will only allow us to go back 120 days for disputes, how much of these transactions is the bank responsible to refund to the customer?
Reg E Dispute from Closed Account
11/24/2019
I had a member who filled out a Reg E dispute for a subscription that was coming out of her account for months. After she filed the dispute she closed out her account. Does Reg E say I have to file the dispute? I don't have an account/membership to give her access to the funds or pull from if this is a valid charge.
