Alabama Bank News

Question: Is a bank required to notify customers of a deposited check being returned? Answer: Yes, Regulation CC, § 229.33(h), requires providing notice to a customer of a check being returned by midnight of the banking day following the banking day on which the ...Read More

In October, the Office of Foreign Assets Control (OFAC) published more targeted guidance for digital asset companies related to compliance with sanctions and best practices for mitigating risks. OFAC’s virtual currency guidance is directed at the entire industry, “including technology companies, exchangers, administrators, miners, ...Read More

Question: What is the current open-end threshold for partial exemptions?  When does it change? Answer: The partial exemption open-end threshold is currently 500 transactions in each of the two previous years and is not currently scheduled to change. There is currently a full reporting ...Read More

Question: Can you give us some tips drafting an MSA for a joint advertising campaign to avoid a RESPA Section 8 issue? Answer: As I am sure you have found, “marketing services agreements” is definitely a hot topic. It is still unclear to what ...Read More

Question: We are considering an arrangement with our construction builder customers where they would get a set amount of “credit” (points) for every spec loan closed with us. The points would be eligible to apply discounts associated for an annual trip with the Bank’s ...Read More

Question: Can a bank provide an access device for a home equity line of credit (HELOC)? Answer: This is permissible, with several risk considerations for the bank. Under Regulation Z, § 1026.2(a)(15)(ii), a debit card that can access a HELOC is a credit card. ...Read More

Question: Our bank uses the exception notice for the Regulation V, risk-based pricing credit score disclosures. If a loan applicant withdraws the loan request, is the bank still required to deliver the credit score exception notice to the applicant? Answer: Regulation V, § 1022.72, ...Read More