11/05/2008
What is a risk assessment and what types of things would it cover?
09/22/2008
What position (head teller, loan officer, etc.) of the bank would be the best candidate for our BSA officer? Would it be our compliance officer?
01/28/2008
During our compliance audit we noticed that periodically hold notices are being provided to customers for exception holds that have both exception and case by case checked. Do we need to have our staff send out revised forms that have only the exception hold box checked?
12/03/2007
The Q&A below in the InfoVault caught my attention. Where would I find the exemption for use of the EHL logo for national banks?<dir>Question: I am trying to find the required disclosures to include the following message on exterior signage "100% Financing Available, Low Down Payments and No Hidden Fees." Can you help? Answer: I don't believe any of the information provided in this signage triggers further disclosures. Refer to Section 226.16 of Reg Z (for open-end credit advertising requirements) and Section 226.24 (for closed-end credit advertising requirements). If this is a home loan promotion, you do need to include the Equal Housing Lender logo <strong>(<u>unless your institution is regulated by the OCC</u>)</strong>.</dir>
10/22/2007
When a deposit slip is filled out the cash should be indicated on the deposit slip as cash. How important is this? We have tellers filling out the deposit slips with the total amount of cash as the total amount of the deposit. I know the BSA states "the slip or ticket shall record the amount of any currency involved". Does the amount of cash need to be in the line for currency and the deposit total line? Do the regulators really check this?
04/16/2007
Do you have any guidance on advertising a CD rate special on outdoor letter boards? Section 230.8(b) of Reg DD makes it perfectly clear that use of APY alone is insufficient, "Annual Percentage Yield" must be used at least once. Outdoor media is no exception to this. Can you offer some additional guidance/reference materials for me to assess the risk of non-compliance with this particular requirement? Is there some hidden reason that I'm missing where regulators acknowledge the wide appeal/recognition of APY by consumers? A potential solution may be to see whether we can have the sign provider create a special letter-board insert potentially the width of 2 or 3 characters that reads "APY is Annual Percentage Yield". Before we went down this path, I wanted to underscore the compliance risk we would be taking if we didn't find a solution.
03/19/2007
Our marketing department would like to issue lapel pins to our officers that say, "15.5, ask me how". This is in reference to an interest bearing checking account product that we have. Even though it does not say "15.5%", I still believe this would be viewed as a percentage rate by the regulators and therefore requires all of the information that goes along with a triggering term (including the term "Annual Percentage Rate"). Their contention is that the individual wearing the pin can make all of the required disclosure. I'm not so sure that this is acceptable. What do you think?
01/02/2007
What forms of secondary ID are the regulators looking for? Also, is it recommended to have two forms of ID for authorized signers on a corporate account?
10/09/2006
From a marketing perspective, are Requests for Proposals (RFPs) considered marketing materials? Do the regulators view them as such?
07/31/2006
What are the Reg D requirements for notices of excessive transactions? By this I mean do we have to produce a notice at the time of the excessive transaction, or is it enough to provide a monthly notice at the time a statement cuts?