05/28/2007
We are designing a brochure for our Gift card program. We work with a vendor on this program; the vendor receives part of the fee for a card purchased and the bank receives the remainder. We sell these cards to both customers and non-customers. A gift card does not fit the definition of an "account" under TISA. Would we have to disclose the fees on the brochure? Could we say "ask about the fees" or do we have to disclose the fee schedule? Or could we be silent on the fees? Or is this a deceptive advertising practice? I am also reviewing the contract with the vendor to see if the vendor requires us to disclose fees when advertising.
05/21/2007
Do we need to give everyone who opens an account with us a Check 21 disclosure or do we give them only to customers that get checks returned with their statements?
05/07/2007
During a recent FDIC audit, we were told that returned deposit notices involving checks that had been converted into IRD's needed a Check 21 disclosure notice enclosed with the notification/check. Our account opening disclosures already have the Check 21 disclosures included with them. Is this correct or were they mistaken?
04/30/2007
We want to change our procedures for opening accounts to include asking for an email address, with the purpose being for email alerts and ads. I cannot find where this would not be allowed as long as we have the unsubscribe feature. Is this correct?
04/09/2007
I have just completed a television advertisement for the CU which shows at the very end the NCUA and equal housing lender logos. My question is, is it necessary to say in the oral presentation "Member NCUA" or "equal housing lender" or do the logos have to appear for a specific period of time?
03/19/2007
How long do we (Deposit Operations) need to keep customer statements returned for unknown address? Take into consideration that we would keep an Excel log of the ones that come back along with the reason for return.
02/19/2007
If a customer lives out of the country and wishes to have a branch receive their monthly statements, is this permissible? If so, what rules apply?
02/12/2007
What is the rule about financial statements? We have customers that will not bring them in when requested and we are in need of them. What does the regulation say?
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?
10/23/2006
Does a Power of Attorney cover entry to a Safe Deposit Box if it is not specifically addressed in the Power of Attorney?