RSK.IQ.Staff, Author at RSK Compliance Solutions LLC • Page 42 of 122

RSK.IQ Question of the Week 7/2/18

Posted on July 2, 2018June 29, 2018 by RSK.IQ.Staff

Regulation DD and Change in Terms

Issue/Inquiry

The Bank has purchased another financial institution. It will be converting the deposit products of that institution to its own. The changes will apply to nine products and consist of the following:

A $25 maintenance fee if the balance falls below a certain amount (old product had either no fee or a $10 fee)
Multi-tiered interest (old product had one tier on five of the products)
An increase in the minimum balance required to earn interest on four of the products

A letter will be sent 30 days prior to the change, providing customers with the new Truth-in-Savings Act (“TISA”) terms on the account. If the letter describes in detail what is changing, does the Bank need to provide a TISA disclosure with the letter? If the Bank begins only offering the new products to new customers during the 30-day period, does it need to update its website product pages on the first day it offers the products to new customers?

RSK.IQ Question of the Week 6/25/18

Posted on June 25, 2018June 25, 2018 by RSK.IQ.Staff

CRA and Credit for Scholarship Donations

Issue/Inquiry

The Bank is considering making donations to schools offering scholarships to students. Although the schools might not be located in low to moderate-income census tracts, the Bank is hoping to make such donations on the condition that the funds be directed to students from low to moderate-income backgrounds. Would the Bank be granted CRA credit for this type of contribution?

RSK.IQ Question of the Week 6/18/18

Posted on June 18, 2018June 18, 2018 by RSK.IQ.Staff

Mortgage Loan Periodic Statements and Bankruptcy

Issue/Inquiry

The CFPB Mortgage Servicing Rule changes that affect periodic statements include additional disclosures for consumers in bankruptcy that are now supported by the Bank’s core processing system. Is the Bank required to make changes to its loan bills for customers in bankruptcy? If so, what changes must the Bank make? Does the size of the institution or how many loans it has matter? If the Bank is required to make changes to its current loan billing verbiage and format, when do these changes need to be implemented?