Do we need a separate repository for our deposit documents?
What are some common trust exceptions that banks track with ticklers?
We have engaged an external IT security company to provide strong security for us. Do we still need a cyber incident response plan?
Are there any compliance issues with regards to a change of address on a commercial loan. i.e authorized signers on change of address form, verbally submit a change with no written signature obtained?
We are discussing accounts you can merge on online banking (so that the agent can see the fiduciary account along with his/her personal accounts with a single log-in) for example:
1.) Rep Payee
2.) Escrow Agents
3.) Power of Attorney-Appointed Agents
4.) UTMA Accounts
The custodian has been challenged as to whether or not you can or can't combine with a parent’s accounts online banking.
Is there any legislation or case law or statutory basis for which we must decline these requests or is it discretionary?
A new account (joint) for an existing customer with her adult daughter was opened and had 2 signatures required for withdrawal coded on account and contract. The customer already had Internet banking and the new account was not blocked from being accessed. What is the liability of the bank for funds transferred to an individual account via internet banking?
We are mailing out our statements and also provide eStatements for our customers, but if a customer does not want their statement at all can the customer elect not to receive a statement if we provide them with a form to have them elect not to receive a statement?
Our financial institution wants to offer atm/debit cards to minors. I was hoping for some direction with the following: <ul><li>Do we need specific information about this in the EFT disclosure?<li>If we offer cards to minors between 14-18 is there a discrimnation issue?<Li>I am assuming we need to have a liability form signed by the parents any thoughts on what should be included?</ul>
We offer an Overdraft Privilege Product, and to date, have allowed bank employees to use it just as the non-employee customers. We're looking at drafting a new Employee Overdraft policy and would like to know if it would be discriminatory to not allow our employees to have the Overdraft Privilege Product? What do you hear from examiners on this issue?
With the new amendments to Reg DD in 2009 about ATM balances including ODP amounts, is it enough to have separate balances, i.e. Ledger Balance (actual) and Available Balance (including ODP)? That is what we have currently. I just want to make sure we are in compliance if the available balance doesn't actually state that it includes ODP.