Reg E
Hello. I'm actually a CIO looking for some compliance guidance. I'm afraid our compliance officer is a little overboard in her requirements and I was just wondering how other banks were handling the following situations: 1) Start Date for Reg E dispute Tracking – Our Electronic Banking department has our our branches complete and email a form for Reg E disputes so that the tracking process can start immediately. However, we also have to wait on the signed customer documentation. This means two forms for the branches and back office Operations to keep up with. Do other banks have a process for this or does back-office just get notified when they get the signed documentation? 2) Interest – Regulation E states that provisional credit must be provided within 10 days including interest where applicable. We’ve never provided interest on provisional credit in the past and haven’t had any problems or audit exceptions regarding this. However, our compliance officer states that since it is in the Reg, we must figure out a way to incorporate this into our procedures. Do other banks calculate interest on provisional credit or simply provide the amount of the claim? Many thanks for any compliance guidance you can provide!
I must be overbaord too! I agree with your compliance officer. 2. Written confirmation of oral notice. A financial institution must begin its investigation promptly upon receipt of an oral notice. It may not delay until it has received a written confirmation. 6. Correction of an error. If the financial institution determines an error occurred, within either the 10-day or 45-day period, it must correct the error (subject to the liability provisions of §§205.6 (a) and (b)) including, where applicable, the crediting of interest and the refunding of any fees imposed by the institution. In a combined credit/EFT transaction, for example, the institution must refund any finance charges incurred as a result of the error. The institution need not refund fees that would have been imposed whether or not the error occurred.
Thanks so much for the quick reply. I was posting out of ignorance and definitely didn't mean to disparage our compliance officer! [;)]
kiaware is absolutely correct
I think you can go for some compliance training. I know one company they are providing training for compliance. For more information pls check http://www.compliancepanel.com/