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HMDA
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The loan term would be the remaining term assumed by the assumption agreement. If an ARM I would opine the introductory rate period would be the period to the first rate change date that takes place after the assumption agreement was entered into.
This is assuming the assumption is reportable under Reg. C.
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CRA
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Most likely this would be outlined in the original issue prospectus.
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General Discussion
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What about this part? " or any call for telemarketing purposes to a residential telephone subscriber"
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Lending Compliance
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Just one comment. If the modification is considered a refinance under 1026.20(a), then all Regulation Z provisions apply, not just TRID.
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Lending Compliance
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No
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BSA/AML/CIP/OFAC Forum
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I'm hung up on the number of SARs she says they receive. Apparently my little bank files a statistically significant number of SARs if they only received 119,000 in a two year period.
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Chat! - BOL Watercooler
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Congratulations Susielou!!
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General Discussion
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I will check into that....thank you!
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Lending Compliance
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Sounds good to me. Thanks all!
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Operations Compliance
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Also wondering on your logs do you record the amount of cash received in each deposit?
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Need to Remain Anonymous
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Re: CRM
by INBanker
@ 05/08/24 04:19 PM
Depends on what you want to get out of the CRM tool and how your institution is setup, I suppose. I've previously worked at a non-depository lender where we logged pretty much every customer contact. The number of times we were able to use those notes to resolve customer issues was too numerous to count.
For example: Mary calls the bank for her balance on Tuesday. On Friday her account is overdrawn. She calls the bank upset because she claims the bank told her the wrong balance. Two ways this conversation can go.
1) "I'm sorry Mary I don't know who you spoke to on Tuesday but I don't show that was your account balance at the time".
2) "I see here you spoke to Jim on Tuesday and he informed you your balance was $200, which is what I also show the balance was at the time"
I'd prefer #2 as the bank and the customer, personally.
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CRA
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We have a hotel that we are refinancing from another bank. It's located right on the edge of a middle and moderate income tract, but actually in the middle income tract. I'm sure it draws employees from the surrounding moderate income tracts.
Since it's a not a build or a rehab, but rather just a straight refinance, could we still this qualify as a CD loan under the idea of job preservation?
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CRA
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Thanks, Len.
I'm told we don't have a good way to get the underlying information about the specific loans in an SBA pool. Would it make a difference if the pool only consisted of loans $1mm or less?
Curious to see if anyone has any experience getting the info needed to qualify an SBA loan pool for CRA credit.
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Flood Compliance
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Thanks so much! Have a great day!
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Operations Compliance
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Hello. Was hoping to get some opinions on remittance transfer questions that i have.
1. For remittance transfers done by phone, I believe a bank would almost be forced to utilize the separate pre-payment disclosure and receipt rather than using the combined disclosure. I state this because use of the combined disclosure triggers the need to provide proof of payment. And proof of payment must be provided in writing or electronically in a retainable form "...when payment is made for the remittance transfer." And comment 5 to 1005.34(a) tells us that payment is made "... when a sender provides cash to the remittance transfer provider or when payment is authorized." So it would be impossible to provide something in writing over the phone at the time the customer authorizes a wire. They aren't there in person to hand it to. I guess providing it electronically might be an option, but that comes with its own issues. Would you agree or disagree with me here?
2. If a remittance transfer is to provide funds in a foreign currency, we provide an exchange rate on our disclosure as required. My understanding is that exchange rate is only good for that day, as they can change daily (someone please correct me if I'm wrong here). Say the bank has a wire cut-off time of 3:00, but a customer comes in after that cut-off time to request a remittance transfer in a foreign currency. Do we have to send them away and tell them to come back on the next business day since the exchange rate we would provide on that day might change the next day when the wire actually goes out? Or can we estimate that exchange rate using the exchange rate for the current day, disclose to the customer on that day when they come in, and send the wire out the next business day since the cut-off time had already past?
Thank you in advance for looking this over.
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General Discussion
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1030.3(f) - Disclosures can have multiple decimal places, advertising is limited to two decimal places. There are no concerns here provided that the information on the disclosures/ads is accurate.
(f) Rounding and accuracy rules for rates and yields. (1) Rounding. The annual percentage yield, the annual percentage yield earned, and the interest rate shall be rounded to the nearest one-hundredth of one percentage point (.01%) and expressed to two decimal places. For account disclosures, the interest rate may be expressed to more than two decimal places.
Technically, in disclosures, the only item than can be expressed to more than 2 decimal places is the interest rate.
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BSA/AML/CIP/OFAC Forum
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I've been looking at SARs for a bank and noticed something I have not seen other folks do, but I don't think it's necessarily wrong. Just wanting to see if anyone here that completes SARs do the same.
First, on the first page of the form on 2 Financial Institution Note to FinCEN they are just putting a brief descriptions of the reason for the filing. I understood that to be when it applies to a guidance/advisory or geographical targeting order, but the regulation does say "etc." and other areas of note say "other activities". So they are putting "structuring" , "check fraud", "transactions below CTR threshold". Anyone else including these 'other activities' there?
Second, in Part II #48 "Product/instrument description" they are putting the date/dollar amount/check number, or dollar amount/date/account type. I always see this in the narrative or a separate attachment if there is a lot. There isn't instructions for 48 except the product marked in 45 and/or instrument marked in 46. So if they are checking deposit account and US currency or personal/business check it could apply. I just feel like that reads more like some type of commodity, stock, etc. I have not ever seen anyone put anything in 48 yet.
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BSA/AML/CIP/OFAC Forum
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Nevermind that was replaced in 2019
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FCRA
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Thank you for your help!
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Chat! - BOL Watercooler
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Susan Buckner - 72 - best known for playing Patty Simcox in the movie Grease.
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CRA
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We already financed the land with a previous loan, but the borrower is refinancing that loan to add money to purchase additional mobile homes to rent out.
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General Discussion
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If all check processing involved remote deposit capture (by the bank or by bank customers) or mobile bank deposits, MICR ink would probably become a thing of the past. However, many checks get converted into ACH transactions for processing, and the systems that read checks to convert them to ARC, BOC, POP and RCK (and other) ACH items read the MICR line to create the ACH transaction data for routing number, Receiver's account number, and check serial number.
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BSA/AML/CIP/OFAC Forum
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I wish that was how it worked here!
I think I have it figured out though on how to proceed. Thank you all for your input.
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BSA/AML/CIP/OFAC Forum
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Q - For us, your outline is mostly correct, except we have someone in the BSA Department who makes the changes. But it's fine for someone in IT to handle this function as well.
We don't ask committees for approval on operational items. We simply report the changes to the Committee during the next scheduled meeting. The Committee can, of course, request more information or challenge the changes.
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Lending Compliance
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Thank you! I appreciate that advice and we will be ensuring our process is adhered to!
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