Ability to Pay rules for Secured Credit Cards
Question: Hi Heather, I have a question regarding a new credit card product that we are about to launch. This card will have a pledge of shares to back it as collateral. Because of this we will not require a credit pull or verification of income. Will this create a problem if the applicant is […]
SCRA and Career Servicemembers
Question: Hey Heather! We have a member currently serving full time in the US Army. He just got orders for an overseas deployment and will be leaving on the 26th of this month. He currently has a signature loan and an auto loan with the credit union. Is this when we lower his rate to […]
Altered Check: Who Pays?
Question: Hi Heather, We have another financial institution requesting funds back for a check that is fraudulent. Can you clarify for me when we as a credit union are responsible to take the loss and when we can deny the request? In this situation the check was altered. The payee was changed to someone else. […]
Visa Rejected the Dispute, Can the Credit Union do the Same?
Question: Hi Heather,Our credit union has a question about a Visa Dispute we filed for a member. Some background: The member is disputing several transactions made through Cash App going all the way back to at least December, most of them in the member’s name. The member claims to not have noticed the transactions leaving […]
Disclosing Seller-Paid Fees on the Closing Disclosure
Question: I had a question on Real Estate agent commissions. We have always shown seller-paid items on our borrower’s (buyer’s) Closing Disclosure (CD). We had a Real Estate agent ask us not to show the seller-paid commissions on the buyer’s CD. Do you have any thoughts on this? Is there anything in the regulation that […]
CTRs for Multiple Accounts with Same Ownership
Question: Hello, Heather! I was hoping you could help me with a question regarding a CTR filing. We had a member come in and withdraw cash from his business account that he owns. Then in a separate transaction he withdrew cash from his personal account. The purpose of both transactions are the same, and the […]
Expelling Members Who Have Caused a Loss
Question: Good Morning, Heather. We are a federal credit union. In the past, whenever a member has caused a loss to the credit union, we have charged off their loans and closed their account no longer allowing them to be a member of the CU unless they pay us back in full. We have never […]
Advertising Certificate Rates on Outdoor Signs
Question: Hi Heather. Our credit union is going to offer a limited time certificate promotion. The car wash next door has a reader board that we have used in the past for marketing, but we’ve never advertised rates. If we are going to offer a 12 month certificate at 5.25% with an APY of 5.27%, […]
Do I Need to Fill-in Every Field on a SAR?
Question: Hi Heather,Do you have a trick for remembering how to complete the “Selling Location” or “Paying Location” and the suspects role “Purchaser/Sender” or Payee/Receiver” fields on the FinCEN SAR form? I always trip myself up for cash structuring SARs. Answer: See Q&A #18 on FinCEN’s SAR FAQs: 18. How do we complete Item 56/68 […]
