Common Violations and Risk Areas - Continued
By Amy Kudlacek
In my last blog, I provided my notes regarding the Common Lending Violations and Risk Areas for the FDIC Grand Island Field Office. Below are my notes regarding the deposit violations:
Truth in Savings
230.4(b) - account disclosure requirements
If violations resulting in monetary losses to consumers, regulators can request a bank provide "voluntary reimbursement".
230.8(c) - advertising requirements with APY
Advertising disclosure continue to be a problem for many banks.
Electronic Funds Transfer
205.11(c) - Provisional Credit
Many banks fail to resolve errors or provide provisional credit within 5 days on VISA point of sale disputes or 10 days on other error disputes.
Expedited Funds Availability
229.10(c)(1) - $100 rule on case-by-case holds
Many banks fail to make the first $100 available to the customer by the next business day when placing a case-by-case hold.
229.57(b)(2) - Not providing Check 21 disclosure with a returned substitute check.
Non-Deposit Products
343.40(a) - Not providing sale of insurance disclosure
As I stated in my previous blog, you may want to review your banks procedures to ensure you are still in compliance. You may find that additional training is in order.