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CRA and SBA Paycheck Protection Program
Issue/Inquiry
The Bank is participating in the Small Business Administration (“SBA”) Paycheck Protection Program. The loans should be closing soon. Are these loans considered small business loans or community development loans for Community Reinvestment Act (“CRA”) purposes?
CAN-SPAM Act and Sending E-mails to Customers
Issue/Inquiry
The Bank obtains the e-mail address of customers at account opening. It wants to send them communications, some of which will provide updated news about the Bank. Does the Bank need to have a disclosure or do the customers need to “opt in” before the Bank can e-mail them? Should the Bank have a policy regarding such e-mails?
Regulation D Reserve and Earnings Credit
Issue/Inquiry
The Bank is looking to update its products that have account analysis features offset by an earnings credit. The earnings credit is calculated on the customer’s average available balance for the month minus a reserve requirement of 10 percent. This gives the Bank a net average available balance which is used to calculate the credit. Are there any regulatory requirements associated with this reserve amount?
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