08/11/2024
Can you provide an example in which the authorization warranty by an ODFI can recover additional reimbursement for a consumer Receiver who has been hit with a long series of monthly unauthorized ACH debits to his account?
08/04/2024
When I have sent the request to return an ACH debit a customer disputed and it was within Reg E 60 days from the statement date we have been challenged on the return. Are we violating Nacha or Reg E when we return the ACH when it's past 60 days from posted, but not 60 days from statement date?
08/04/2024
How do we handle a situation where the ODFI does not provide a proof of authorization, but sends the contact information of the originator?
07/28/2024
When is the CFPB likely to issue a final regulation making banks over
$10 billion in assets cut their overdraft fees back to a breakeven amount or start
treating overdrafts as extensions of open-end credit subject to Regulation Z?
07/28/2024
If we elect to update our disclosures on the circumstances that may trigger overdraft charges, do we have to disclose the order in which we post debit and credit items to deposit accounts?
07/28/2024
Two of our depositors receive direct deposits of both VA and Social Security benefit payments to their joint checking account. We received a garnishment order naming one of them as judgment debtor. When we looked back over the past two months’ account activity, we found two direct deposits for Social Security benefits and two for VA benefits. These customers routinely move their SSA and VA deposits into their savings account soon after they are received, and appear to meet their monthly bills using monthly IRA disbursements.
Can we treat the SSA and VA funds in the savings account as “protected funds”?
07/21/2024
Can a personal certificate of deposit account have authorized signers?
07/21/2024
Our institution has chosen not to charge NSF fees on ANY ATM/debit
card transactions whether they are one time or recurring. Having said that, if we
are in an APSN situation at end of day and the account is now overdrawn, we
DO charge an Overdraft Fee (even if the only item causing the overdrawn
balance is the ATM/Debit card transaction). Would this be perceived at
UDAP/UDAAP? Additionally, both NSF fees and OD fees are the same amount.
07/14/2024
We have a HELOC that is maturing 7/15/2024. Both borrowers are deceased. The son was paying the interest due each month. He does not qualify to put the loan in his name. We have agreed to give him a 90-day extension to either sell the home or get financing to payoff our loan.
I have a copy of each of the borrowers' wills. Everything was bequeathed to the son and daughter equally. The daughter was named as the personal representative of the will and was authorized and empowered to sell, dispose of and convey all property, of every kind and character, which is owned at the time of death. My question is, who has to sign the loan extension documents? Is it the personalrepresentative of the estate?
07/14/2024
What regulation does collateral inspections fall under?