Review Alliance: Did You Know?
Did you know it’s important for the bank to keep track of all active NOW Accounts? Remember NOW accounts are not the same classification as business/commercial interest bearing transaction accounts.
• NOW Accounts can be maintained in the following:
o 1 or more individuals including sole proprietorships
o Not for profit organizations, operated primarily for religious, charitable, educational, political, philanthropic, or similar purpose.
o Officers, employees, or agents of public entities
o Funds held in the banks trust department
you know that that it’s important that your Regulation DD account statement
description of fees verbiage must match the fee schedule description or even
the product brochure of services for those same fees, to avoid customer
confusion and avoiding of any UDAAP consequences. Small
things such overdraft fee vs OD fee, this fee description should be exactly the
concerns can cause monetary penalties as well as reputational risk.
Did you know NACHA Rules require the ODFI to set and monitor exposure limits for each ACH Originator or Third-Party Sender?
- Procedures should be in place to monitor entries originated across multiple settlement dates.
- A best practice would be to set daily limits as well as per item limits.
- The Bank’s ACH policy should include guidelines for when a limit is exceeded.
- A verbal approval would be a violation of the Bank’s ACH policy if it is stated that written approval is required.
you know that as a best practice it’s important to get updated loan
applications at least annually?
ensure the bank retains updated information for their customers
Covers the bank by giving permissible purpose to pull credit
you know that
reconciling monthly statements from Credit Reporting Agencies is a best practice
to help ensure the bank is only utilizing the service for applicable credit
requests? This practice can help ensure information is being obtained and used
permissibly, as well as help ensure compliance with the Fair Credit Reporting
in hand with that, also:
you know that it’s a best practice to have your Credit Reporting Agency
statement include the names of the customers that have credit pulled? This will
help ensure all customers credit who is pulled has requested a bank product
requiring a credit report.