Bankers Alliance Compliance Corner
Editor's Note: The following was submitted by Bankers Alliance. LBA, through its subsidiary Louisiana Bankers Service Corporation, has partnered with Bankers Alliance to give banks access to three compliance-related programs. Click here for more information.
Q: What is the required charge off date on past due unsecured loans?
A: For overdraft accounts, there is a standard of 60 days for charge offs. However, there isn't one for loans. This would depend on your bank's policies.
"In addition, overdraft balances should generally be charged off when considered uncollectible, but no later than 60 days from the date first overdrawn." Joint Guidance on Overdraft Protection Programs, p. 4 (Click here to view.)
Q: If a customer calls and asks about our current rates do we need to include a statement of “annual percentage yield” along with the rate?
A: In any oral response to a consumer inquiry on deposit rates Regulation DD requires that you state the annual percentage yield. The interest rate may be stated in addition to the annual percentage yield:
"(e) Oral response to inquiries. In an oral response to a consumer's inquiry about interest rates payable on its accounts, the depository institution shall state the annual percentage yield. The interest rate may be stated in addition to the annual percentage yield. No other rate may be stated." (Click here for more information.)
Compliance Alliance offers a comprehensive suite of compliance management solutions. To learn how to put them to work for your bank, call (888) 353-3933 or email info@compliancealliance.com and ask for the membership team.
Did you know that the term ‘annual’ for delivery of the bank’s Annual Privacy Notice does not strictly refer to the calendar year?
- Customers must receive the notice at least once during any consecutive 12-month period.
- The notice must be provided during the following calendar year in which you provided an initial notice to the customer.
- New privacy notices are not required for new products or services.
Did you know that certain words and phrases are prohibited when filing a currency transaction report?
- Prohibited words include Customer, DBA, Not Applicable, Non-Customer, and Unknown.
- Filing instructions list 15 prohibited words and phrases.
- These terms are deemed nonconclusive and specific information is required for filings to assist the reviewers of the report.
Review Alliance is an independent group of compliance specialists offering banks deep-dive audits of their existing transactions, recommendations about program enhancements or guidance on future safety and soundness. Virtual Compliance Officer was added in 2020—a new shared service-model using bank-dedicated compliance officers; perfect for monitoring and guiding your bank remotely. To learn how to put them to work for your bank, call (833)-683-0701or email info@bankersalliance.org and ask for the membership team.