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Entries in Policies (2)


FDIC Issues Revised Guidance on Third-Party Payment Processors

The FDIC recently issued Revised Guidance regarding account relationships with payment processors that process RCC and ACH payments on behalf of third-party merchants (the “Revised Guidance”). Such account relationships are relatively common for financial institutions, but come with the risk of association with unscrupulous third-party merchants serviced by the payment processor. The Revised Guidance focuses on the need for caution with respect to payment processors and merchants that have a higher risk profile for unauthorized payments and fraudulent/unlawful activity, such as those involved in telemarketing and certain internet-based industries.

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Joint Accounts - their impact on estate plans

Joint accounts provide many benefits to customers, and it is important that those same customers clearly understand what they’re doing when they set up joint accounts. Joint accounts can significantly alter a person’s existing estate plan because it is not controlled by a person’s will. Joint accounts are, therefore, sometimes the focus of contentious estate litigation, which can turn on the circumstances of how the accounts were set up.

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