TOPIC: Regulation

45 day advance notice - open end credit

Person at a bank ($158MUSA)
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. 

    right of offset

    Manager at a credit_union ($586MUSA)
    Anyone out there in Massachusetts.  When you do offsets, do you have language that you put on your receipts pertaining to Mass Law chapter 485 of the acts of 1975?

      Requirements when at $3Billion and $5Billion in Assets

      SVP at a bank ($2.9BUSA)
      i am looking to see if anyone can point me in a direction where it will tell me any additional requirements we will have to follow when over $3Billion and then over $5Billion. this would be more for safety & soundness and independence requirements. it is not for compliance requirements. maybe there is some type of grid or something out there??

      we are and FDIC public bank with a holding company

      i am aware of FDIC Part 363 but that is all i can seem to find and this is not my forte..


        ESign / Electronic Signature /eVault for Implementation of System of "Control" vendors

        CTO at a bank ($855MUSA)
        Hello, we are working on a large project to get as many docs (loan, deposit, commercial, and many others) from paper signatures to eSignature.  We have done much research on the rules/regs and specifically we are advised by the legal experts that this will work as long as we are compliant also with "Control" of the transferrable record.  So we are looking at how best and who to use for the implementation of system of "control".  Other FI's have implemented eVaulting to provide a secure chain of custody for the electronic records and use TOLEC (Transfer of Location of Electronic Contracts) software.  So two of the companies that have been recommended for the eVault piece are SPeRS (Standards & Procedures for Electronic Records & Signatures) and/or ESRA (Electronic Signature and Records Association) to implement electronic, signature, disclosure and eVaulting solutions to deal with the "Best Evidence" concern.  

        My question is has anyone worked with an eVault company like SPeRS or ESRA and if so, what do you recommend as the best option for this piece of the requirement for eVaulting?I am not familiar with either of these companies so wanted to see if anyone had any information you could provide and/or recommend if you have already been through and established this process.  

        Thanks in advance!

          Compliance Training - Vendor vs in-house custom training?

          Employee at a credit_union ($12.3BUSA)
          I've noticed that some financial institutions are ditching the paid online vendor training (we use BVS) and moving toward all custom created content, whether it's in person, eLearning or WebEx type.  Has anyone moved from vendor provided compliance training to creating your own training?  I'm wondering how long it took, how it was phased in and was it worth it? Also. has anyone been able to tie custom training to better understanding of regulatory requirements and reduced findings/issues?  Thank you.