Breaking Archive

Q: Must a bank have RDFI procedures in place to ensure a 30-day written notice is provided to account holders receiving Federal benefit payments prior to the actual closing of the account?  A: Yes, you must give 30 days’ notice prior to closing an ...Read More

Q: We have a joint account owned by three people. When filling out a SAR, do we include a Part I on an all account holder even if one had no transactions or involvement? A: While a CTR has an assumption that all joint ...Read More

By Ryan Cochran, Waller, and Mitch Galloway, Galloway Consulting As the nation’s healthcare industry grapples with the impact of COVID-19, many hospitals are facing financial pressure. This article will address how COVID-19 impacts the finances at hospitals, and some immediate ways hospitals can respond. ...Read More

Q: Does our ATM have to notify a non-customer of the bank that our bank is going to charge a fee and what the fee amount is? A: Yes, this is an explicit requirement under Regulation E, as provided below: (b) General. An automated teller ...Read More

Question: For the electronic delivery of a periodic statement under Regulation E, is the bank required to notify a customer that it is available? Answer: For customers that would like to receive their statements electronically, they must provide E-SIGN consent first–but once they provide ...Read More

by Michael Odom Relying on the CARES Act, the Federal Reserve Board (Fed) established the Main Street Lending Program (MSLP) to facilitate lending to small and medium-sized businesses in order to help maintain operations until conditions normalize. The program provides a relatively low-risk mechanism ...Read More

Q: If our bank chooses to continue to impose the six-transfer limit as it used to be set out in Regulation D, does a telephone transfer count toward the six transfers per month? A: Yes, in general, these would usually have been counted in ...Read More