We are changing our passbook savings accounts to regular savings accounts or money market accounts. The account numbers and signers are not changing. The only thing changing is the account type. Can any signer on the account make the change and sign for the change, or is it required that all signers sign for the change so that everyone on the account acknowledges it?
If we provide Reg DD disclosure data such as the APY on business account periodic statements, would that require us to follow the other Reg DD requirements such as providing subsequent disclosure notices if we change an account service charge? Our host system is tying accounts together based on Social Security Numbers and Reg DD is triggered by the CIF and not by the individual accounts.
I am using the Website Compliance Checklist that is available on BankersOnline. Question 17 on this form, "Is the term "Interest Rate" used and not just "Rate"?
I am having some trouble finding what Reg or guidance this might be related to. I'll need to explain to the Audit Committee and Board why it matters and right now I can't find any guidance.
When advertising time deposit rates with a bump rate feature, what all is required?
Also how do you disclose a rate ceiling, as a rate or APY?
We are rolling out a new rewards program. For members who maintain multiple accounts with direct deposit and have an average balance of at least $XX,XXX, we’re going to rebate X% of each debit card purchase, up to $100 per year.
I was reading some compliance discussions that noted if the credit/rebate is tied to a service instead of just opening and maintaining an account, then it would not be considered a bonus or need to be reported on a 1099-INT. In this case, the accountholder would first need to qualify for a certain level on our rewards program based on their products and balance. However, to receive the rebate, they would need to use their debit card to receive the rebate reward up to $50.
We are leaning towards the rebates not being a bonus or reported on a 1099-INT as payment is triggered on the use of their debit card, not solely on opening or maintaining an account. Thoughts?
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?
Is the bank required to disclose that a bonus paid will be considered interest and be reported on a 1099-Misc? Should the information be
disclosed in the advertisement of a bonus?
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?
We are currently in the process of changing our fees. Some fees may increase and some fees may decrease. With that said do we still need to
send a notice to customers 45 days in advance of the changes?
We are offering members a $100 incentive bonus if they open a checking account with direct deposit which would start within 60 days. We understand all of the disclosure requirements for the $100 payment. The argument is, must we disclose in the ad that the $100 will be reported as interest to the IRS? We of course will be sending the member a 1099-INT and reporting it to the IRS, but are we required to disclose that?