08/29/2011
Are changes coming for Free Checking? We have heard that it has to be totally free if "Free" is in the title (no daily overdraft fees, NSF fees, no fees can be charged).
10/04/2010
Regarding automated telephone banking systems, customers can currently inquire (get account balance and info) by phone with their account number and last four digits of their SSN. If they want to transfer funds between their accounts, they must complete an application. My bank wants to give automatic access to transfers too. I'm concerned about Reg E issuing access device rules. Is calling the number and following the steps, "requesting" the access? We have new operations personnel who say all banks do this automatically. Other banks don't have customers fill out a form or call and talk to someone, it is all done through the automated phone system. Does this comply?
07/12/2010
We do a lot of targeted marketing in our bank. Our operations and marketing departments have approached our compliance team with a proposal to market our overdraft service to customers who don't yet have the service, but have had checks returned for insufficient funds in the last six months. Currently, this service allows qualified customers' accounts to go overdrawn by from $200 to $300 provided they cover their overdrafts within fourteen days. We would market it in two layers, with an option for customers to accept basic coverage for checks and ACH items only, and another to accept coverage for checks, ACH and ATM/debit card transactions. We will include all the compliance disclosure, opt-in and confirmation requirements for card transactions required by Regulation E. Are there any compliance concerns related to targeting this marketing to that group of customers?
05/24/2010
We have several loan production offices. They don't have cash drawers, are not listed as branches, and they don't service the deposit customer walking in off the street. Do we need signage such as the FDIC stickers? What if a courier for the bank picks up some proof work where only our employees make deposits instead of running to a branch?
05/17/2010
We are a national bank regulated by the OCC. Are we required to include the EHL or EOL logos when creating an advertising banner that generally touches on some services/products such as, "we offer commercial and SBA loans?" No terms, APRs/APYs, etc. are included.
05/03/2010
If we sent out a notice of delayed availability and it was wrong, do we have to send a new one to the customer in all cases?
03/01/2010
Marketing wants to sponsor a half-court contest at a game at a local high school. The booster club would sell tickets for a chance to take the shot. The bank would provide the prize money. Can we advertise or show our sponsorship with a banner at the game? I said no, that it would be sponsoring a lottery.
09/14/2009
Our Lending Department has created a “fact sheet” to be given to realtors. The understanding is that these fact sheets would not be provided to consumers. Do you think I could consider these as not being an advertisement, and therefore not having to worry about trigger terms?
05/25/2009
How can the bank cut cost in risk and compliance management for third parties?
05/04/2009
How can the bank benefit from the BITS Shared Assessment Program?