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Compliance Q&A: Bank Travel Club Considerations

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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

CAPITOL NOTES: Legislature Returns to Capital City; Special Session Likely to be Called by Governor

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The Alabama Legislature convened last Tuesday to start the 2022 Regular Legislative Session. In addition to their usual activities of crafting both the General Fund and Education Trust Fund budgets, lawmakers will also consider a couple of tax-reduction bills introduced by Sen. Arthur Orr ...Read More

Compliance Q&A: Access Device for a HELOC

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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

Compliance Q&A: Open-end Credit Card and Due Date Considerations

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Question: For an open-end credit card account, can a due date on the monthly billing statement vary if the usual due date is a Sunday? Example: The due date is usually the 12th of every month. However, 9/12/21, is a Sunday, therefore, the billing ...Read More

Compliance Alliance: FRCA and Risk-based Pricing

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QUESTION: The bank currently provides the risk-based pricing notice in accordance with model forms H-3 and H-4, under the FCRA and Regulation V, for loans secured and not secured by residential real estate, respectively. The bank does not employ a credit scoring model or ...Read More

Compliance Q&A: E-Sign Act and Notice to Customer

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Question: Must the bank follow the E-Sign Act requirements if providing notice of nonpayment to a customer electronically? Answer: The commentary to § 229.33(h), clarifies that a notice can be provided by email or fax. However, only Regulation CC, Subpart B, requires conforming with ...Read More

Compliance Alliance: Returned Check Notice

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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

Compliance Alliance: OFAC Issues New Guidance Directed at Virtual Currency Industry: What You Need to Know

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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

Breaking, Compliance Q&A, Publications

Q: What is the current closed-end threshold for partial exemptions? When does it change? A: The partial exemption closed-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

Compliance Q&A: Partial Exemption Considerations

Breaking, Compliance Q&A

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

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