What are the requirements needed to open an estate account?
In general, what types of accounts are covered by the new Prepaid Account rule?
Our bank would like to keep away from overdraft situations where we are debiting a customer’s checking account for any overdraft situations. Do we have any options?
Is there a second prong that applies to the definition of what is, or is not, a Prepaid Account?
My understanding is that to be covered by the prepaid rule the account must be marketed and labeled as “prepaid” or is redeemable at multiple, unaffiliated merchants for good or services. Is that correct?
Does the Person-to-Person (P2P) definitional requirement also cover transfers to businesses?
We are a small community bank and the submission to the CFPB of our Prepaid Account agreements looks to be burdensome. Is there any way out of providing such disclosures?
From your review of the new beneficial ownership rule, in your opinion, will both prongs of this rule apply to our customer's customer?
If the OFAC list now contains a name that matches our customer’s name, should we immediately close the account?
There were two dates in the Federal Register announcement of this new rule, a July 11, 2016 “effective date” and a May 11, 2018 “applicability date”. Which one do we follow?