Vendor Guru Q&A - Operations

Electronic Management of SAR Files

Latest Operations - Transfers Topics

Calculating the De Minimis Amount for Overdrafts

03/28/2011

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?

Statement Opt Outs

03/21/2011

Can a customer “opt out” of receiving bank statements entirely? Thus, they will not receive a paper statement or an E-statement.

What Comprises an IRA Rollover?

02/07/2011

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?

Conservator Makes Transfers to Personal Account

01/10/2011

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?

Changing Joint Account to Trust

10/25/2010

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 Can this be superceded or does the account need to be closed and reopened under a new account number?

Exceeding Transaction Limits Online

10/18/2010

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?

Automated Telephone Banking Systems

10/04/2010

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?

Reg D and Withdrawal Limits

08/09/2010

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?

Changing the Model A-9 Opt-In Form

07/19/2010

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?

Exceeding Withdrawal Limits: the Next Step

06/28/2010

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?

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Reg E Dispute from Closed Account

11/24/2019

I had a member who filled out a Reg E dispute for a subscription that was coming out of her account for months. After she filed the dispute she closed out her account. Does Reg E say I have to file the dispute? I don't have an account/membership to give her access to the funds or pull from if this is a valid charge.

Close Account Due to Account Abuse?

11/24/2019

We have a customer who we recently refunded $630 of Returned NSF Fees and Continued Negative Balance Fees to after stating the items came thru sooner than scheduled (Reg E). The account went positive for one day and has now been negative for 17 days since (62 days NSF last 12 months). She has another account that is currently positive but that account has also had 41 days NSF. Can we close her accounts due to account abuse or failure to maintain account in a responsible manner?

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