11/09/2009
We currently have e-statements available for our e-banking customers and will be adding e-bills. Any e-banking customers that have e-statement and a loan account within their profile, will be converted to an e-bill for these loans. We will continue to send both the e-bill and the paper bill for a two to three month time period. There is no way to have these customers agree or accept a revised agreement without shutting off all e-statements and have them agree again, which is not a good option from a customer service perspective. Will we be OK if we send an email communication to all e-banking customers of the pending change and have a message printed on the loan bills alerting customers to the pending change? e-statement customers agreed to receive all disclosures and statements electronically when they initially signed up for e-statements.
08/17/2009
Can you please tell me what charters/policies are required to be disclosed on our website? Also, does our Whistle Blower Policy need to be included on our website?
12/15/2008
In developing a esignature process for consumer closed-end loans with a goal to transfer the paper, are we required to comply with both the ESIGN Act and the UETA?
03/24/2008
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.
02/04/2008
Are there restrictions on opening accounts on the internet for residents of states where the state chartered bank has no branches?
10/22/2007
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.
09/24/2007
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?
05/15/2006
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?
04/10/2006
For tiered-rate APRs posted on our website for consumer loans, do we have to use the phrase "as low as" or other verbiage?
10/03/2005
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?