In regard to the changes in overdraft protection programs, can the de minimis amount where we do not charge a NSF fee be the total of the overdraft daily or is it a de minimis amount per check?
Can a customer “opt out” of receiving bank statements entirely? Thus, they will not receive a paper statement or an E-statement.
A client transfers funds to an IRA, then wants a disbursement and then closes the IRA. He returns before sixty days to put the funds back into a new IRA. Would this be considered a rollover?
Alisa is a court appointed conservator on an adult account. She also has a personal checking account with the bank. Should she be allowed to make online or recurring transfers from the guardian account to her personal account? I told her it's not allowed, but she said other banks let her do it. Could this be true?
I want to change a joint account to a trust. Can this be superceded or does the account need to be closed and reopened under a new account number?
When we have a customer who exceeds the transaction limitations on a savings account due to online transfers, we restrict him from online banking. If he also has a sweep set up for overdraft protection, we do not remove the sweep, since this is not what put him over the transaction limit. Is this a violation of the Reg? Should we restrict him from online banking as well as remove the overdraft protection sweep?
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?
With regard to Reg D, when it states that withdrawals are limited to six per month or statement cycle, which do we have to go by for monitoring purpose if the calender month is different than the statement cycle? Our savings accounts are on a quarterly cycle instead of monthly cycle; are we limited to six per month or six per quarterly statement cycle?
I would like to know how I should change the Model A-9 Opt-in form to include our line of credit product. Do you have a sample to show?
When a savings account has exceeded the withdrawal limits, can the funds be moved into a MMA? What are the guidelines for requiring an account to be closed?