If a customer "opts in" to have their statements provided in their online banking, are we obligated or regulated to send them a paper statement AND online statement the 1st month their statement cycles?
If we offer an account without check writing, does a "wet" signature need to be obtained during account opening or can that step be eliminated?
We submitted an ACH PPD on 6/23/11. We received it back on 6/28/11 with Return Reason Code R01. Is this considered a late return?
In most cases, when an EFT error (ACH) is reported to us, the investigation is initiated immediately and completed within 10 days. Our bank requires written confirmation for all EFT errors that are reported. We realize that without written confirmation, it does not delay the initiation or completion of the investigation. However, what are our requirements for crediting if the customer does not give us written confirmation within 10 days? Do we have to follow the provisional credit rules? Or do we just let the reported error “hang” until we get that written confirmation?
Reg. E contains a small bank limited exclusion for pre-authorized transfers. We still offer a passbook savings account that allows only direct deposit of payroll. There is specific staff commentary to 205.9 indicating a statement is not required in this instance. Can the argument be made that the direct deposit is a pre-authorized transfer so as a small bank we are excluded from the error resolution notice requirement?