How long should we keep typical complaint letters?
It looks like "a bank must provide a potential customer written disclosure of its availability policy prior to opening an account and prior to accepting a deposit if the account has not yet been opened." I wonder when an account is considered "open." For instance, we do not take a paper application in conjunction with opening a deposit/savings accounts. We just explain to the potential customer what checking and or savings products we offer and give them brochures. Then we get personal information about them, and help them pick the deposit product they want. We provide disclosures, and accept a deposit to fund the account.
Is this acceptable?
Would a purchase/home renovation draw down line for 6 months then convert to a 240 month term be disclosed the same as a construction to permanent loan since renovations are being made and not construction from the ground up?
Are lot loans exempt from HPML?
Can employees resolve complaints on the spot, or should there be a formal written complaint required for this?
On a reserve line of credit tied to a DDA account. Is it necessary to provide a monthly statement when there is no activity? Zero balance, no advance nothing owing.
I need the Reg that talks about making a statement available to the customer. I was told once that you cannot stop the statement from printing unless you offer estatements because the customer must receive a statement with the verbiage on the back.
We are interested in advertising our introductory interest rate for our HELOC on the side of a bus. Should we treat it just like a newspaper advertisement with all of the same disclosures based on the triggers?
We had a system glitch that improperly coded the accrual basis. It should have been coded as 365/actual but was instead coded as 360. These are consumer customers. Of course we are going to correct the accrual basis and credit the account for the overcharged amount. Do we need to do anything else re contacting the consumers? Is this found in Z anywhere?
If we are placing a Reg CC hold based upon a reasonable doubt of collectability, are we required to make the first $200 available the next day?