RSK.IQ.Staff, Author at RSK Compliance Solutions LLC • Page 40 of 122

RSK.IQ Question of the Week 8/13/18

Posted on August 13, 2018August 13, 2018 by RSK.IQ.Staff

Regulation DD and Disclosures for DESAs

Issue/Inquiry

If the Bank offers Landlord/Tenant Deposit Escrow Security Accounts (“DESA”), is it required to provide disclosures to the tenants/sub-account holders?

RSK.IQ Question of the Week 8/6/2018

Posted on August 6, 2018August 3, 2018 by RSK.IQ.Staff

FDIC Official Statement and Equal Housing Lender Legend and Logo on Promotional Items

Issue/Inquiry

If the Bank has its logo on an item, such as a bank pen in the lobby or a little giveaway at an event, does it have to include the FDIC membership logo as well? If a loan program is referenced, as with a mortgage loan slogan, does the Equal Housing Lender legend and logotype need to appear?

RSK.IQ Question of the Week 7/30/18

Posted on July 30, 2018July 27, 2018 by RSK.IQ.Staff

Regulation P and Sharing Information Under a Joint Marketing Agreement

Issue/Inquiry

The Bank has a joint marketing agreement with a credit card company, which issues credit cards in the Bank’s name but performs the underwriting and makes the credit decision. The company has requested a list of customer names, addresses, and social security numbers, so that they can run a credit search and decide on what card to offer a customer. The Bank’s Privacy Policy allows it to share personal information for joint marketing with other financial companies. Would the Bank be permitted to provide this customer information to the credit card company?