TOPIC: Notices


Manager at a credit_union ($854MUSA)
As I am sure you are like us, we have been getting a ton of requests from other FIs for a subordination.  If you deny a subordination request (due to LTV) is it required to send out an Adverse Action Notice?  I didn't think that it was required but wondering how others handle this?

    Courtesy Pay ATM Notice

    Employee at a credit_union ($1.4BUSA)
    My credit union is looking into adding a Courtesy Pay notice on our ATMs as a best practice. Does anyone have an Courtesy Pay notice they are willing to share? Thank you in advance!

      Change to Hours of Operation Notice?

      Employee at a credit_union ($1.4BUSA)
      Hi there, 

      My CU is changing the hours of operation for all of our branches. We know we need to notify our members, but I'm having trouble finding guidance on what exactly needs to be done and within what time frame? Could anyone advise or point me in the direction of the rules/regs that would have this info?

      Thank you!

        Back Office to Back Office Check Recall

        Manager at a credit_union ($174MUSA)
        I was advised to send a "Back Office to Back Office Check Recall" form to the Research and Adjustments Department of another FI, in order to recall an item that was sent through the Fed, but I have been informed that the funds are being held by the other FI. 

        Does anyone have a form or letter that you have used for this purpose, that you would be willing to share with us?

        The Fed is unable to assist through a cash letter adjustment request, as the item does not fit into any specific criteria for claim type.
        Thank you in advance for any assistance you can provide, it is truly appreciated.

          California Franchise Tax Board Order to Withhold and notification to customer

          Employee at a credit_union ($905MUSA)
          Looking for some advice for California institutions and what you do for the FTB Order to Withhold when there are no funds in excess of the protected amount.

          If we received the order and reviewed the account and it had protected funds so we have nothing to remit to the FTB, do we still need to notify the customer that we received the notice? My thinking is yes, we still do even if we are not withholding any amounts because we need to send that letter to the customer that came with the order.

            Tax Form 1098

            Manager at a bank ($287MUSA)

            Is the bank required to issue a Form 1098 (Mortgage Interest) on a mobile home that is not permanently attached to the land?  We would have just the title to the mobile home.

              45 day advance notice - open end credit

              Person at a bank ($205MUSA)
              I am going in circles trying to determine if this requirement applies to our product.  Any help would be greatly appreciated.
              We have an unsecured open-end line of credit that does not have credit card access, it does have a floor/minimum rate and our new software (in the middle of testing new software) is giving a warning that states the following: the part of the regulation that I have been reading is 1026.9(c)(2)(v) and 1026.55(b)(2) and I just don't know for certain if it truly applies to the product.  Basically I need to know if we should be providing this advance notice or not. 
              thank you in advance for any help provided. 

                Reg CC Script for Employees

                Manager at a bank ($1BUSA)
                Hello!  Does anyone have a script for their employees to use to answer questions regarding the new Reg CC dollar amounts?  We provided notice of the Reg CC changes on our statements and have received some questions.  Looking to standardize responses.  Thanks in advance!

                  Denial reasons for denied applications placed in the wrong channel

                  Manager at a credit_union ($4.3BUSA)
                  Hello! From time to time, we receive consumer loan applications that were meant to be business loan applications. These are self-serve applications through our website and selected the wrong product.

                  The current process is to withdraw the application placed in error and for a new application to be started by the applicant with our business services team. The denial reason of "we do not offer the type of credit requested" seems to fit the situation. 

                  Is 'withdrawn' acceptable for the original application in this situation or should we be using the denial reason above?

                    Privacy notice opt out online form

                    Employee at a bank ($6.8BUSA)
                    We are changing our privacy notice to state we share with affiliates and non affiliates and including a online web form for customers to opt out. Are there any requirements or guidance on how the form needs to look?  Can we provide just one box to opt out of everything?

                      post dated check notices

                      VP at a bank ($55MUSA)

                      I am looking to send a letter to borrowers notifying them that our policy has changed and that Post Dated checks will no longer be held until the date written on the check.  The check will either be deposited or returned..  I was hoping someone might have a sample they are willing to share.