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Latest Compliance - Adverse Action Topics

Negative Information Disclosures w/ Adverse Action

10/29/2012

The new bank I am with gives Negative Information Disclosures with Adverse Action Notices. I don't see how this is correct since we have not issued credit to them therefore we have no negative credit to report personally. Am I correct? I've looked at FACTA and TIL and found nothing I can show the lenders.

Keep Consumer Adverse Action for Five Years?

10/22/2012

Regarding Adverse Actions - Everything we see says we need to keep consumer ones for 25 months. Our compliance person, now says we need to keep them for 5 years because of the Consumer Financial Protection Bureau. Have you heard anything about this?

ECOA Mortgage Loan App & Underwriting 30 Days

06/25/2012

For ECOA purposes only is a mortgage lender required to have a loan application taken, processed and submitted to underwriting within 30 days so that an underwriter can issue a conditional approval? Please explain when the "30 days" starts ticking for the lender to issue a decision? Can a decision be made just from the 1003 or does a fully processed package need to be submitted?

Adverse Action Notice when Closing ODP?

06/18/2012

We have members that have not used their over draft protection (odp) as far back as we can go on the system, their checking, and savings accounts are dormant. Do we need to send an adverse action when we close their overdraft protection(odp)?

Adverse Action- Info Obtained from Outside Source

05/14/2012

My question deals with Adverse Action Notices...section # 5 the disclosure of use of information obtained from an outside source. I fully understand the first block for denials based on a credit report and all the information that now must be included. I am confused at the last box that is saying our decision is based on information obtained from another source other than a credit reporting agency. If we have to decline a client for the condition of their real estate and we received that information through an appraisal report should we be utilizing that box? Again this is when the denial decision was NOT based on any part of a credit report or credit score?

Adverse Action Notice for Insufficient Collateral?

04/09/2012

Are you required to send an adverse action notice, when applying Reg B or FCRA, when the Customer is denied due to insufficient collateral? In this situation, the Customer credit report was run and the credit score was not a factor concerning approval.

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Certificate of Deposit

09/29/2024

I am new to the compliance function so I apologize if this does not make sense. My question addresses Reg DD and a CD interest payment date vs. maturity date. Here is an example: a CD term is 6 months and interest is paid every 30 days. Since there are more/less than 30 days in some months the interest payment date does coincide with the maturity date, so there are generally a few days between these dates. I am unable to find anything in the TISA reg about this. How and when is interest paid in relation to the maturity of the CD?

Unauthorized Authorized Debits

09/29/2024

If a customer authorizes someone to use their card and gives them the PIN for a specific transaction, and that someone uses the card for additional transactions that were not authorized by the customer, is their any negligence by the customer for giving the card and PIN for the first authorized transaction? What are the requirements according to Reg E ?

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