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Compliance Q&A: Joint Accounts and Suspicious Activity Reporting

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Q: We have a joint account owned by three people. When filling out a SAR, do we include a Part I on an all account holder even if one had no transactions or involvement? A: While a CTR has an assumption that all joint ...Read More

Compliance Q&A: Commercial Loans & Flood Insurance

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Q: Commercial Loan Scenario—Collateral is located in a SFHA, but is in a non-participating community. Because federal flood insurance would not be available, can the bank close the loan without flood insurance coverage? A: If the property is in a non-participating community, then flood ...Read More

Hospitals Financially Impacted by COVID-19

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By Ryan Cochran, Waller, and Mitch Galloway, Galloway Consulting As the nation’s healthcare industry grapples with the impact of COVID-19, many hospitals are facing financial pressure. This article will address how COVID-19 impacts the finances at hospitals, and some immediate ways hospitals can respond. ...Read More

Compliance Q&A: ATM Fee Notifications for Non-customers

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Q: Does our ATM have to notify a non-customer of the bank that our bank is going to charge a fee and what the fee amount is? A: Yes, this is an explicit requirement under Regulation E, as provided below: (b) General. An automated teller ...Read More

Keep an Eye on Your Capital

Board Briefs, Breaking, Publications

by Charles Moore, Bradley Banks have played a crucial role these last few months as the COVID-19 pandemic has swept across the world. Through Paycheck Protection Program loans, payment deferments, and other initiatives, banks have provided significant assistance to people and businesses of all ...Read More

Compliance Q&A: Reg E and Electronic Statement Delivery

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Question: For the electronic delivery of a periodic statement under Regulation E, is the bank required to notify a customer that it is available? Answer: For customers that would like to receive their statements electronically, they must provide E-SIGN consent first–but once they provide ...Read More

Thoughts on the Main Street Lending Program

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by Michael Odom Relying on the CARES Act, the Federal Reserve Board (Fed) established the Main Street Lending Program (MSLP) to facilitate lending to small and medium-sized businesses in order to help maintain operations until conditions normalize. The program provides a relatively low-risk mechanism ...Read More

Compliance Q&A: Join Accounts and Reg CC

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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

Compliance Q&A: Regulation D and Transfers

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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

Compliance Q&A: Adverse Action Reports

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Q: The bank is denying an application for a deposit account, but we did not pull a credit report to make this determination. Is an adverse action notice required? A: If the bank did not use a credit report to deny the deposit account ...Read More

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