Regulatory Guidance

Debit card dispute – hotel charges - January 21, 2020
When you “lend” someone your debit card to pay for a hotel stay, you’re pretty much stuck with whatever gets charged to it, even if he stays a couple of extra days. I wonder if any bank discloses that little wrinkle on “unauthorized” charges to their cardholders...
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Condensed Statement - October 28, 2019
Banks do not need to create work and continue doing things “the way we always have.”...
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Mutilated Currency - October 16, 2019
“"Mutilated", "Contaminated", and "Unfit" currency.” What is the difference and what do you do with it, in particular mutilated?...
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Reg CC hold notice violations - August 19, 2019
I have reviewed several recent months of deposit holds. The availability dates reflected on the notices are all correct; however, several of the notices neglected to check some of the correlating reasons for the hold boxes. For example: The $200 was checked, the case-by-case hold box was omitted, the Exception Hold box was checked but the boxes under the Exception Hold box relating to exceeding $5000 and the box 1st $5000 is subject to the Case-by-Case Hold...
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Large Dollar Return Item notifications - July 23, 2019
Is letting a bank of first deposit know that a large item is being returned a courtesy, or a requirement?...
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NOW accounts - June 17, 2019
NOW account eligibility continues to confuse me now that regulations state that banks are allowed to open interest-bearing business accounts. I just noticed two profit-sharing business accounts that were just opened with our First Preferred interest-bearing accounts with special higher rates. When I research online, it still sounds like partnerships, LLCs, corporations and business trusts are not eligible. Can you help clear the smoke on this for me?...
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Hold notice deviates from model - June 11, 2019
Automation can certainly make tasks easier, but it can also cause compliance problems. When automation of Reg CC holds notices threatens to mess with the statement of the reason for a hold due to system design constraints (character count limits), someone needs to rethink the design...
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Reg CC Large deposit hold – $200 basis - April 1, 2019
As much as we all wish the Fed and Bureau get their update of Regulation CC finalized, it seems pretty clear that just clearing away all the extraneous stuff about local and nonlocal checks and changing the $100 rule to a $200 rule won’t make the regulation easy to deal with. But there is info in the Commentary that helps explain some of the challenging text in the regulation itself...
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Medical marijuana - December 24, 2018
Ahh, the fun topic of medical marijuana. Medical marijuana is now legal in our state, and the dispensaries aren’t currently set up, but things are starting to get moving. We are a largely a correspondent bank for smaller community banks. Our position on marijuana is: we won’t directly bank it (lending or deposits)...
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Lottery risk - October 30, 2018
Our marketing department is considering doing a lottery under a different name. They have suggested a system wherein there's consideration for a reward, drawn at random, and limited to a small prize pool...
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