All in Regulation CC

VIDEO: Requirements for Reg CC Lobby Disclosures

VIDEO: Requirements for Reg CC Lobby Disclosures

Paula Parras
Regulation CC

In this Compliance Clip (video), Adam talks about the requirements for lobby disclosures under Regulation CC. In other words, Adam discusses and gives an examples of how the notice that tells customers about a bank’s hold practices should be displayed in a bank’s lobby area, based on the requirements of Regulation CC. A transcript of this video is now available.

OCC Issues Civil Money Penalty Against a Bank Officer

Adam Witmer
Regulatory Update, Regulation CC

On February, 2022, the OCC issued a consent order against Craig Meader of the First National Bank of Kansas. This is one of the enforcement actions that OCC has taken against national banks, federal savings associations, and individuals currently and formerly affiliated with national banks and federal savings associations. The OCC issued a civil money penalty proceeding against Meader on the basis of his activities while serving as the President and member of the Board of the bank.

Fed Updates Reg D FAQs

Adam Witmer
Regulation D, Regulatory Update, Regulation CC

On 5/13/2020, the Federal Reserve updated their Frequently Asked Questions regarding Regulation D and the recent changes to the rule. Among other things, the updates to the FAQs include the following clarifications:

  • Question 3 answers the question of whether or not the recent amendments to Regulation D are temporary or permanent. As explained in the answer, the Federal Reserve does not expect the changes to be “short term” and “does not have plans to re-impose transfer limits,” but could if future conditions warrant it.

  • Question 13 explains what we have been saying the last few weeks: that the recent Reg D changes do not cause savings deposits to be subject to Reg CC hold requirements.

Video: Increasing Reg CC Thresholds to Avoid 5 Year Adjustments

Video: Increasing Reg CC Thresholds to Avoid 5 Year Adjustments

Adam Witmer
Regulation CC

In this extended Compliance Clip (video), Adam take a little bit different approach to our Compliance Clips and discusses the pros and cons of increasing the Reg CC threshold amounts above and beyond the new mandated amounts, in attempts to avoid another required adjustment (and customer redisclosure) in 5 years, when the rule is set to again adjust for inflation. In other words, some financial institutions are considering increasing their hold amounts from $225 and $5,525 to something like $300 and $6,100 (watch the video to see where the $6,100 comes from) in order to avoid another adjustment in 5 years - but are these amounts enough?. This Compliance Clip takes a deep dive into the thought process some compliance professionals are taking to determine their course of action regarding the upcoming Reg CC changes. If you are a super-nerd when it comes to deposit compliance, this clip is for you.

Hold Notice for New Accounts

Hold Notice for New Accounts

Adam Witmer
Regulation CC

In this Compliance Clip (video), Adam talks about the hold notice rules for New Accounts. Specifically, Adam answers the question as to whether a hold notice is required when using a new account hold under Regulation CC. For those interested in…

Reg CC Change In Terms Notice Timing Requirements

Reg CC Change In Terms Notice Timing Requirements

Adam Witmer
Regulation CC

Adam uses this week’s Compliance Clip (video) to answer this question: Is a change in terms notice required for the upcoming July 1, 2020 changes to Regulation CC, and if so, is advance notice to our customers required? The reality is that this single topic is causing a lot of confusion in the industry and many have been told incorrect answers to this question. Therefore, Adam sets the record straight in this short, free video. Click the link below to watch the video.

10-Step Implementation Plan for Reg CC Changes

10-Step Implementation Plan for Reg CC Changes

Adam Witmer
Regulation CC

This video outlines a 10-step plan that can be used to implement the recent amendments to Regulation CC that have required compliance by July 1, 2020. While the Regulation CC amendments may appear to be minimal changes to the actual rules, the impact to financial institutions is going to be much more significant. In fact, there are plenty of things that need to be done by July 1, 2020 to ensure compliance, and this video will provide you and your team with a framework for doing just that. (And if you aren’t responsible for implementing the Reg CC changes, you might consider forwarding this on to your colleagues who are going to tackle these cumbersome changes.)

Summary of Reg CC Changes for July 2020

Adam Witmer
Regulation CC

In this article, we provide a summary of the Reg CC changes that financial institutions must comply with by July 1, 2020. In addition to the summary, this article provides a 10-step implementation plan for complying with the recent changes. Now is the time to get started implementing the new Reg CC rules, and it is our hope that this article can assist you in a successful implementation of the new rules.

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