Most Popular Technology Content
FDIC Insurance Coverage
12/13/2010
Customer A has a $300,000 line of credit with a $200,000 balance that is secured by $300,000 in bank CDs. The bank is closed by FDIC. How does the FDIC consider the CDs securing a loan when figuring out insurance payouts? In this case, would the FDIC use the CDs to pay off the loan and pay the customer $50,000 in proceeds, or would they pay out $100,000 (net of CDs after the loan was paid off)?
E-statements and Reg E
12/06/2010
We offer e-statements to customers. When someone signs up, he is provided the Reg E disclosure electronically at that time. Do we need to have a link to the disclosure for future reference, and specifically, the Reg E part of reviewing a statement for errors? Would a link be sufficient for people to access at any time if the language is not included on each statement?
NSF notices via email?
12/06/2010
Our operations department wants to consider implementing the following: all customers who have signed up for e-statements will receive any NSF notices via email. We have an encryption system (Zixmail) available, so they would likely go out that way. Would this be covered under our existing e-statement disclosure, or should we have those customers sign a second authorization?
Flash Drives and Data Security
12/06/2010
Between the potential for customer files and account trials to walk away and the possible introduction of viruses, I am curious as to what kinds flash drive controls (if any) are being implemented and/or if regulators have started questioning this.
Notice on ATM
11/29/2010
It seems the proposals as to what fee disclosures should be on an ATM have been going on forever. At one time they stated we had to disclose this by sign on the machine and on the screen. At some point they said the fee amount needed to be disclosed in the notice. The final regulation reads like the disclosure could be on the machine or on the screen. There is no mention of disclosing the fee amount for foreign transactions. Can I assume we only need to post the notice on either the screen or a sign on the machine now, and can I assume we do not have to post the fee amount?