Vendor Guru Q&A - Compliance

Latest Compliance - Applications Topics

Does a Fax Equal a Phone Call?

03/15/2004

Under Regulation B, is an application received via fax treated the same as one received via telephone?

Warren Dennis: A Fair Lending Legend

03/01/2004

On January 31, 2004, we lost a fair lending legend. Warren Dennis was an individual who made a huge difference in the world of fair lending.

CIP Record Retention

03/01/2004

Question: We know that records must be maintained for our Customer Identification Program. We are debating how to do this. Do you have any advice?

SAR reporting

03/01/2004

Question: We offer credit cards and handle quite a few applications that appear to be fraudulent or incomplete in one way or another.

Prequals Under HMDA

03/01/2004

What is the defintion for prequalification under HMDA? Is there any instance in which a refinance could be considered a prequalification? Should a prequalification include a property address?

Complaint Resolution Under RESPA

02/02/2004

I am in the process of reviewing and updating all of our compliance forms for our residential mortgage applications. On our current RESPA Servicing Disclosure, we state that any complaint resolution must be handled within 60 days of receiving the customer complaint. I am looking at a version (I assume current) in software we just purchased that states the complaint resolution needs to happen with 60 "busines" days. Does the "business" day statement meet RESPA requirements?

Clear & Conspicuous: A Federal Reserve Standard for Disclosures

12/01/2003

We saw it coming. When the privacy regulation was promulgated, the agencies had to set standards for notifications.

RESPA and a "reasonable" fee

12/01/2003

With regards to RESPA section 8 kickback provisions: The bank is considering using a third party to track insurance coverage for the life of the loan. New loans will be charged a fee of $65 at closing. The third party is proposing to convert our existing portfolio at $2.50 per loan. The contract also states that the third party is not requiring the bank to use them exclusively for this service, but in practice no other company will be used. Is there any guidance on what constitutes a "reasonable" fee in order to avoid potential section 8 violation of receiving a thing of value in exchange for settlement services?

Servicing Disclosure on Denied Applications

10/20/2003

If a customer obtains a loan application, completes it, and mails it back, we decide within 3 days to deny the application, do we still need to send a mortgage servicing disclosure under RESPA?

Loan Apps and CIP Changes

10/06/2003

Reg B This is regarding the changes in the Uniform Residential Loan Application. Do you know if anyone is taking into account (while changes are being made) the changes that will be put in place by the USA Patriot Act? I am referring to the additional information required to be collected at application to identify the borrower.

Common violations may surprise you

04/07/2024

What are some of the more common violations examiners find today?

Revoking Provisional Credit That Isn't There

04/07/2024

According to Reg E, if I need to reverse provisional credit from a customer and they do not have the funds in the account in the amount of the reversal, can I proceed even though it will leave the account in the negative? The customer has been notified verbally of the reversal and I will send the reversal letter via mail, but they have made no attempt to deposit the money to cover this. Can I proceed, regardless of if the funds are available and still be in compliance?

Broadcast a report on bad official checks

04/07/2024

If a bank has fraud on the banks official check account, who does the bank report that to? As we get notifications on other institutions fraud official checks we are unsure of how that information gets sent out.

Are Cash Advances Required

04/07/2024

Can a bank offering cash advance services through Mastercard choose to stop offering that service?

Bank Completed Corporate Resolutions Risks

03/31/2024

What are the pro's and con's of New Accounts completing various Resolutions when opening business accounts? I was advised by legal, that if we use ione, it needs to be board approved and we better know how to complete them accurately. If they are this binding or legal of a document, is it best to not use them? Our system generated resolutions are complicated and we are not completing them consistently.

Latest Compliance - Applications Topics

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