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Compliance Questions & Answers

Compliance touches every corner of community banking, from operations to customer interactions. Discover key areas like internal controls, policy development, and training programs that keep your bank aligned and accountable.

Section 604 permits a person, including a bank, to obtain a consumer report for a legitimate business need for the information including in connection with a business transaction that is initiated by the consumer; or to review an account to determine whether the consumer continues to meet the terms of the account.

Reference: FCRA, Section 604(a)(3)(F).

For the purpose of part 328, safe deposit boxes and credit products are excluded from the definition of "non-deposit." Therefore, there is no requirement under part 328 for an IDI to include such a disclosure in marketing material for these products.

Reference: FDIC Q&As Part 328 Final Rule Question V.1

A disclosure delivered in an electronic format will not meet the requirement to provide disclosures in writing under a given regulation (e.g., Regulation Z or DD) unless it meets E-SIGN requirements specifically provided by the relevant regulation.

Reference: E-Sign Act Requirements, Fed. Consumer Affairs Update, Sept. 2014.

The Security Officer must report on the effectiveness of the Security Program annually and when updates are made to the program.

Reference: FED 12 CFR 208.61; OCC 12 CFR 21; FDIC 12 CFR 326

The financial institution may issue one notice with information related to multiple accounts of an account holder.

Reference: 31 CFR 212.7(g).

The requirement applies to any designated loan, including consumer and commercial loans where a building or mobile home and personal property secure the loan.

Residential Building Examples:

  • Single family dwelling
  • 204 family residential building
  • Other residential building containing 5 or more residetnail units
  • Mixed use building in which the total floor area devoted to nonresidential uses is less than 25% of the building's total floor area, this includes: condominium, apartment, hotels, motels, tourise homes, rooming houses where the normal occupancy is six months or more

Non-residential Building Examples:

  • Commerical buildings
  • Office or Retail Space
  • Wholesale Space
  • Hospitality Space
  • Buildings where the normal stay is 6 months or less including condominiums, apartments, hotels, motels, tourise homes, rooming houses
  • Houses of Worship
  • Schools
  • Recreational Buildings

Reference: 12 CFR 339.3; Interagency Flood Q&A 2022 Determining the Appropriate Amount of Flood Insurance Required; Amount 3 and 4.

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