03/19/2007
If an application is withdrawn by a borrower are we required to give them the Reg V "Notice to Home Loan Applicant" disclosure?
01/15/2007
We would like to look into using E-signatures with online applications to open accounts. Does anyone have any suggestions as to where to look for information on the requirements?
11/27/2006
Is it a requirement for a state chartered credit union to post CIP notices on their website? We have it on the membership form on the website but not on the website itself. Compliance wants to get it put on, but Marketing is refusing because of what they call, "esthetic considerations." Where I can find the text on this topic?
10/09/2006
We are finally developing a bank website and will have online application forms. What are the compliance requirements for submitting an online application? We are in need of some good resources for internet banking compliance in general, what resources would BOL recommend?
09/25/2006
With the FFIEC guidelines related to multi-factor authentication, can you offer any information on the VRU/Telephone Banking platform? If banking clients access data via the telephone is the typical SSN/PIN/Account Number input enough to comply with the FFIEC?
08/21/2006
All our applications are taken by telephone. For compliance, what would be the trigger date for the disclosures? Is it the date of the credit report, or would it be the date the borrower accepts the program and the application is considered completed and signed by the loan officer? An application could be taken today and credit pulled, but sometimes it takes more than 3 days to find a qualified program and/or before the borrower accepts the terms. Please advise.
05/08/2006
Can you help me understand the difference between prequalify and preapprove for HMDA purposes?
05/01/2006
We process applications for credit cards issued by a third party, but don't book the accounts in-house. How long do we have to retain records of the denials and approvals and other records pertaining to the credit cards?
03/13/2006
Under Reg B, should the submission of an information package from a potential borrower's counsel or a broker as part of a distribution to several banks in an effort to find interest in a deal be considered an application?
01/09/2006
We have a difference of opinion in our office concerning the application date to be used when we have prequalified an applicant who does not have a purchase agreement, then brings one in a month later. I think the application date is the date we receive the purchase agreement and not the date of the pre-qual. Am I correct?