Regulatory Guidance

Overall Risk Assessment - July 7, 2023
Risk assessments are basic requirements in today’s compliance environment. They’re a part of compliance management and management of the bank needs to understand the importance and buy-in to the time it will take to start from scratch. View Discussion
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Interest accruals after a Bank fails - March 3, 2023
Deposits are insured by the FDIC, but not the interest that was earning. Acquiring banks have options. View Discussion
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Creation of holding company - August 30, 2022
  I am researching notification requirements (regulatory and public) when an FDIC regulated bank wants to be under a newly created Bank Holding Company. How does Federal Reserve Board Regulation Y come into play with a FDIC regulated bank?  I will refer you to your regulator. The BHC will be under the FRB, and the bank […]
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Reg CC, ATM deposit amount change - May 31, 2022
If a bank has deposit taking ATMs with basically no limit restrictions to the amount of a check that will be accepted for deposit ($99,999.00 for example) and due to fraud issues establishes a limit of $20,000, would this enhancement need to be disclosed prior to the change?     In general, section 1005.8(a)(1) requires a […]
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Mobile check deposit fraud - May 31, 2022
An anonymous poster looks for help with some charged-back checks he had mobile deposited. In this case, it looks like he tossed the checks in the trash after depositing them and a dumpster diver grabbed the checks and deposited them at a different bank. After the poster was taken to task for his lack of […]
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ITMs at an LPO - April 18, 2022
Would A + B = a Branch? Would it be seen as a way around the rules? Is it better to ask permission or forgiveness?  View Discussion
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Debit card, digital app - December 3, 2021
Here is the scenario: Customer A gave their debit card to customer B approximately a year ago. Customer A requested the card back from Customer B in Feb 2021. Customer B previously had used the card for Cash App and FB pay charges prior to Feb 2021. Customer A did not notify the bank that […]
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Incomplete online applications - November 1, 2021
Sometimes not having regulatory guidance is guidance and the bank needs to assess the situation and determine a best course of action. Record retention is such an issue...
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Reasonable/Customary Fee Review - March 8, 2021
Ensuring your bank is competitive on fees charged is a good thing, but any survey done needs to be for that purpose and in no way price-fixing minded, and must be meaningful to your area...
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ATM deposit taking at Combination LPO/DPO - December 14, 2020
Interesting issue and great find by Randy Carey as to whether an LPO + a DPO + and ATM is a branch...
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