Regulatory Guidance

Auto-enrolling depositors in overdraft program - July 1, 2015
It’s been almost 5 years since the FDIC issued its then-controversial Final Overdraft Payment Supervisory Guidance, yet questions continue to show up in Bankers’ Threads. This one is about automatically enrolling qualified new depositors and whether that’s accceptable. The answer? It depends. VIew Discussion
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Western Union - June 4, 2015
As banks try to offer international wires and meet Reg E remittance requirements it seems easier to outsource to Western Union, but they want info too. View Discussion
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Tax Refund into wrong Account – Reg E? - May 28, 2015
Your customer messed up and gave the IRS the wrong account number for the direct deposit of his significant refund. And as luck would have it, the number he gave the IRS is an actual account in your bank, but it belongs to someone else. Your customer doesn’t know that. All he knows is he […]
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Random BSA questions - May 28, 2015
Good tips on retention and exam management. View Discussion
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ODP counseling - July 14, 2014
If you are a FDIC regulated bank, it does seem silly to keep sending the overdraft counseling letters every 6 overdrafts if the customer is one that keeps overdrafting regularly. On the other hand, it’s nice to hear from other banks that this is truly all the examiners expect. It’s one process that can be […]
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314(b) information sharing – your take? - April 3, 2014
Participating in the 314(b) information sharing program can be beneficial, but there are responsibilities that come with it. This thread provides good discussion of the pros and cons. View Discussion
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314(b) Information Sharing - April 2, 2014
FinCEN’s little mini-promo for section 314(b) information sharing on Halloween prompted Ken to ask whether bankers find it a valuable tool. Based on this thread, it’s charitable to say the reviews are mixed. View Discussion
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OD Protection for Commercial Accounts - February 25, 2014
This is a good illustration of why it’s a bad idea to assume that just because you do something for individual customers, you ought to be able to do it for business accounts. The issue is boiled down to its essentials — it’s lending. And when you lend to a business entity (as opposed to […]
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AML Model validation - January 6, 2014
Based on this thread things in the BSA world will be heating up again with the new expectations of independent validation. View Discussion
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