Our lender had a request for a reverse mortgage. He provided an Adverse Action Notice, but did he have to, since we don’t offer reverse mortgage loans?
When does the bank have to make ACH direct deposits available for withdrawal?
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?
A customer of ours came into the bank and cashed six checks totaling $29K. Some were drawn off of our bank and some were not. When I file the CTR, what account number should I use in Part I, item 22? Should I use the account numbers from each check that was cashed? Should I use the account number of our customer even though none of the checks that were cashed came from her account? Should I leave Item 22 blank?
I am researching how to determine which Fiduciary/Agency accounts meet the pass-through account FDIC coverage requirements. I would like to know what is customary to request from these potential clients, since FDIC requires that certain conditions are met, for example, deposit terms for accounts opened at the financial institution must match the terms the third party agent promised the customer and how the third-party fiduciary disclosed fees and other terms of the relationship to their clients, Custodian maintains name and ownership interest of each depositor and funds are not co mingled, applicable state law, etc. Do financial institutions require additional documentation or an account holder's certification to verify pass-through eligibility? Any information that can assist me in determining how to identify and verify FDIC pass-through coverage would be greatly appreciated.