Bio:
Lucy is Editor of Compliance Action and President of Compliance Resources, Inc., a company offering compliance support and services to banks. She is also a Senior Associate of Paragon Compliance Group, a company dedicated to providing compliance training. She has more than twenty-five years of experience working with regulatory agencies and financial institutions. Her extensive work experience with regulatory agencies includes the Federal Home Loan Bank Board, the Board of Governors of the Federal Reserve System, and the Federal Trade Commission. As the manager of the Compliance Division of the American Bankers Association, she worked directly with several of the association's banker committees and with regulatory agencies to identify compliance priorities, and to produce resources and programs.
Areas of Expertise:
Compliance Action Newsletter
Compliance Consulting
Compliance Seminars
Training the Trainer Materials
Questions Answered
04/02/2007
We use a credit reporting agency to have a tri-merge credit report pulled for our secondary marketing loans. The credit report is a consolidation of information from all three credit repositories. We denied a loan request due to the information in the credit report. Who do we list on the Adverse Action Notice, the credit report agency with address and phone number, or do we list each of the credit repositories with their address and phone numbers since the credit report is a tri-merge?
04/02/2007
Regarding the Fact Act for internal purposes, if you are reviewing a customer's overall credit quality on his/her HELOC does the FACT letter need to be generated?
03/26/2007
We are looking at offering teaser rates on our money market and HELOC products. Can you please briefly discuss the disclosure requirements and regulatory references that should be reviewed?
03/26/2007
We are considering extending our CRA assessment area to include a portion of the surrounding counties. None of these areas is a MSA or considered distressed. What, if any, compliance issues would we face doing this? Also, is there a maximum percentage of our loans that can be outside our assessment area?
03/26/2007
When closing a consumer account due to stolen checks or a similar reason and opening another account of the same type (same fees, same name, etc.), is it necessary to provide all the disclosures that are normally provided at account opening? This question has come up because we are in the process of changing our account offerings; the new accounts will have different names, fees, etc. The new account TISA disclosures will reflect the new account offerings. When we do a "close and reopen" we can open the same account type as the customer's original account, however, the new account TISA disclosures will not include information on that account type. What is required in this situation?
03/26/2007
Where can I find information regarding credit scores? I would like to know more about the factors that affect the score, good and bad, which is better, some balance or no balance, high limit vs. no limit and closing accounts at customer’s request.
03/26/2007
A bank has made a decision not to make consumer loans to illegal immigrants. If during the course of obtaining information a loan officer determines that an applicant is an illegal immigrant and therefore denies the loan, is the bank required to send an adverse action notice to the applicant based on an incomplete application since not all information regularly obtained was considered, or is the bank even required to send a notice in this scenario?
03/26/2007
Is there a resource that lists all the mandatory training drivers for banks/mutual associations?
03/19/2007
If a bank uses an outside investor to fund a mortgage loan and the credit report is generated from that investor's website and that investor's name is on the report, can the bank impose a credit report fee at closing? The bank is not charged for the report, it is part of the investors "underwriting fee" that is ultimately charged to the customer.
03/19/2007
What disclosures are required on personal loans not secured by real estate when the interest rate structure is in place? Reduced rate structure: Fixed interest rate equal to prime rate at time of inception except that if loan defaults the rate will increase 2%. Floor of 6.5 and ceiling of 10%. Is this considered a variable rate loan and what disclosures are required by Federal law?
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