Breaking Archive

Q: We have a husband and wife who are opening a new joint checking account with our institution. The husband has had an individual account with us for a while, but the wife has never had an account with us. Can we still use ...Read More

Q: If our bank chooses to continue to impose the six-transfer limit as it used to be set out in Regulation D, does a telephone transfer count toward the six transfers per month? A: Yes, in general, these would usually have been counted in ...Read More

Q: When can borrowers with Paycheck Protection Program (PPP) loans submit their loan forgiveness applications? A: As set out in Interim Final Rule #20, borrowers can submit a loan forgiveness application any time on or before the maturity date of the loan—including before the ...Read More

Q: Can the bank convert a HELOC that is getting close to its maturity date into a closed-end, amortizing loan without requiring TRID disclosures? A: Unfortunately, no–if during the loan term a HELOC is converted from open-end credit to closed-end credit, that would trigger ...Read More

Q: If our customer is on a COVID-19-related forbearance plan (and she was current before the bank agreed to the plan), do we use special comment code AW (affected by natural or declared disaster) and code CP (account in forbearance) and will either affect ...Read More

Q: It is my understanding that the aggregate amount of extensions of credit to executive officers cannot exceed $100,000 for Regulation O purposes. If an executive officer has a loan that is guaranteed by FSA or SBA, is the guaranteed portion of that loan ...Read More

Q: If we doubt the collectability of a check that a customer presents to the Bank, are we able to put “an indefinite” hold on the funds? A: While Reg. CC does not specify the allowable duration of an exception hold for this reason, the Reg. ...Read More