Monthly Statement to Passbook Savings Customers
07/22/2018
Do we have to send a monthly statement to passbook savings customers who have external deposits to the account?
07/22/2018
Do we have to send a monthly statement to passbook savings customers who have external deposits to the account?
07/22/2018
If we disclose to our customers in the initial disclosure that all Reg E disputes must in writing and the customer orally submits a dispute, but doesn't follow up in writing, can we deny the claim?
07/15/2018
When it comes to BSA Compliance - If a member/customer withdraws $10K each day for 3 consecutive days, in what circumstance would one not think this is a reportable suspicious activity?
07/08/2018
If a customer lets someone use their debit card and they've given them the PIN, when they fill out a Reg E claim stating another person was unauthorized to use their card, do we have to honor the claim?
07/01/2018
If joint owners of an account make two separate withdrawals at different times of the day from the account which now totals over $10,000.00, is CTR required? Each individual withdrawal was less than $10,000.00.
06/10/2018
For a REG E ATM Dispute we have a customer filing a claim for $700. She filed a police report and states she didn't know the individual. We have proof on video that she came into the bank with the individual in question. The customer isn't responding to our calls and we would like to know if we still need to give provisional credit and/or final credit if this this is the case.
06/10/2018
If an applicant is declined for a loan but then decides to re-apply with a co-borrower is this considered a counteroffer, meaning an adverse action for the first request would not need to be sent?
05/06/2018
We have a customer who wants to refinance a "land only" loan. When the loan was originally done, no flood determination was pulled and no appraisal was completed. When the original balloon came up for renewal in January 2017 we completed a real estate evaluation of the property. The photos of the property showed a large barn (and possibly multiple barns on the property). Now the customer wants to refinance and the officer wanted to know if a flood determination was needed? We suggested that one was needed since a structure was on the property but since the purpose of the loan was consumer and not commercial we weren't sure.
05/06/2018
What are the requirements if a written adverse action notice of denial is provided to the applicant with a counteroffer and then the counteroffer is denied later on during the process of the application? Is the creditor required to send another adverse action notice denying the counteroffer?
04/29/2018
We currently have a commercial/business purpose loan with an action date of 2/13/18. The loan was for 650K (fixed 30yr) that refinanced an existing 150K loan with 500K for improvements to the property to construct 4 single apartments where there were none previously. The existing property is currently business/commercial property. We are looking for clarification on whether you would consider this HMDA reportable.