Regulatory Guidance

Business checking with interest for LLC - February 5, 2018
We have a business customer that is an LLC and they would like to set up an interest-bearing checking account.  Their goal is to earn interest on the account. Our Federal Reserve contact says Regulation Q was repealed and we may pay interest on business checking accounts...
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Reg E vs. NACHA = Investigating disputes - February 5, 2018
What is a bank’s course of action when handling a Reg E claim that an ACH debit was not authorized, and the consumer fails to provide a written statement of unauthorized debit (WSUD), permitting the bank to send back the debit as unauthorized?...
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Social Security ACHs - February 5, 2018
Your customer has allowed other family members to have their SSA payments direct deposited to his account. It’s been going on for months, and you’ve just become aware of it. What should be done?...
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Social Security ACHs - January 30, 2018
Your customer has allowed other family members to have their SSA payments direct deposited to his account. It’s been going on for months, and you’ve just become aware of it. What should be done? This discussion starts out with a question about what would happen if one of those involved should die, but eventually gets to the action the bank must take...
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NDIP Disclosures - September 11, 2017
Examiners take a very tough approach to any advertisement evening mentioning a nondeposit product and an insured product in the same vicinity...
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Holds on cashier’s check, large deposit and other holds - July 10, 2017
Can a bank place a hold on a cashier’s check? May we do so for the FULL amount if we have a reasonable reason? What about the large deposit hold if it’s over $5,000? If you could point me in the direction of easy to read guidance on account holds, I would very much appreciate it...
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Board of directors, compliance officer’s authority - June 26, 2017
This is the blurb from the FFIEC manual about the level of authority needed by a BSA officer for his or her responsibilities: Senior management within the BSA/AML compliance function and senior compliance personnel within the individual business lines should have the appropriate authority, independence, and access to personnel and information within the organization, and appropriate resources to conduct their activities effectively" 
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Gift card, Reg E - May 22, 2017
I’m trying to confirm that we are exempt from the prepaid accounts rule under Regulation E. In my research, I’ve determined we are exempt, but I’m hoping for a little more comfort. We currently sell prepaid gift cards to our state agencies who then give them to employees as recognition or on holidays. The card is MasterCard branded, and it say’s gift card on the front of the card...
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Bill-pay transactions and Reg E - May 8, 2017
We are having a discussion concerning whether or not transactions completed through bill-pay that are paid by check rather than EFT are covered by Reg E. If a customer files a dispute for an unauthorized transaction that was completed using bill-pay and paid by check rather than EFT, is the bank responsible?...
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OFAC at account opening - February 27, 2017
Currently we use FIS Identification Verification as our solution to process the OFAC check when the account is opened. This is a very cumbersome process and we continue to have audit issues - i.e., the CSR saw the customer on our database so he didn't run the program (the account was closed 6 months ago)...
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