Our institution is based in Missouri, but we offer an online savings account. We are wondering about what state laws we use for charging dormant/inactive fees to accounts? Missouri Law is that once an account is inactive/dormant for twelve months we can charge a fee up to $5.00 a month. Then after five years of inactivity, the account is considered abandoned and will need to be sent to the State Unclaimed Property department. If a customer from different states opens accounts online with us, do we abide by Missouri Law or the state law which they reside in?
Can an IRA customer contribute if he or she is 75 and earning income?
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?
When is the 2020 FFIEC BSA Exam manual effective?
Do we have to change our Savings Deposits?
On a joint account, Bob or Betty, if Bob makes a deposit and Betty makes a deposit, do we really have to do four part Is
Is a US TIN enough for a NRA on an interest bearing account?
Can my customer waive and RMD for an IRA?
Can a savings account be charged an NSF fee?
Under Reg D do you have to send out a notice or can you email the customer making them aware of the excessive withdrawals.