We have an officer that is wanting to do away with email and internet because she is afraid of a virus shutting down our system. We have proper firewalls/virus programs etc. How can I explain to her that our virus programs are designed to keep this from happening? She is wanting me to tell her with 100% certainty that nothing will hurt our system. I feel comfortable with the protection that we have however, I cannot guarantee that nothing will happen.
Are there restrictions on opening accounts on the internet for residents of states where the state chartered bank has no branches?
We have started accepting applications for mortgage loans online. Would there be any requirement or need to have a reproduction of the fair housing poster on the site? The regulation says that these fair housing posters should be displayed so that all persons seeking to engage in residential real estate related transactions would be able to see it. In our online process, our customers could theoretically complete the whole loan without ever stepping foot into one of our offices. In those cases, they would never see the poster.
Pay day loan companies are illegal in NC and a customer gets loans from six different companies then finds out it is illegal. He or she is then advised that they don't have to pay them back because they have no recourse against her in NC, so he or she wants to dispute the ACH debits as unauthorized transactions under Reg E and have all the money put back in his or her account. Wouldn't they have to return the credits as well? Also, does the bank have to return any NSF fees involved?
We are considering making loans via the internet. I know CIP and internet security need to be arduous. What other considerations and compliance issues are there?
For tiered-rate APRs posted on our website for consumer loans, do we have to use the phrase "as low as" or other verbiage?
We have a customer who is repeatedly wanting to do stop payments on numerous ACH items, such as quick pay day loans. This customer says that these items are not authorized, but is claiming this every two weeks when they are memo posting to her account and making her overdrawn. What are the rules surrounding a situation like this? Can we refuse to do stop payments all together for this customer on this type of items?
Our organization uses a vendor to service our mortgage loans. The vendor emails trial balance data, (loan numbers, names, balances, etc.) to us. The emails are password protected. Is this sufficient under GLBA or must the emails be encrypted?
We have several customers who are getting payday loans from these companies. Then they come to our bank the next month and make a stop payment request for any ACH amount from ABC Company. We are charging them a one time fee. This is taking up a lot of our time in processing. I know we can close their account out after giving them 30 days notice. Can we charge them every time an ACH item hits from that same company? Some of these customer have 4 or 5 payday loan companies they are borrowing from. Do we also need to have them sign an ACH stop payment form stating they have notified the payday company to revoke the ACH coming out of their account?
A recent survey by PricewaterhouseCoopers in the United States and the United Kingdom reveals a sense that "...