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Latest Compliance - Audit Topics

Stemming The Flood Of Violations

06/01/2002

Examiners find violations of the flood hazard insurance requirements - lots of them. That's bad enough. But on top of the findings are the consequences.

TIL & HUD1 Tolerances

05/06/2002

After a recent audit of our secondary mortgage loans, it was determined that the itemized charges on the final TIL and the HUD1 are always the same even though they are prepared the same date. The Mortgage Department's response is that Oh well! As long as we are within tolerance, who cares. They disagree that they should take precautions to match the final TIL with the HUD1. This position is taken because they have no written evidence in the regulations that the HUD1 has to be in agreement with the final TIL. My stance is that even though there are tolerance, these should be for 'human errors' rather than daytoday practice. Is there some regulatory opinion in this regard?

BSA: FRB Enforces BSA

05/01/2002

FinCEN isn't the only agency taking aggressive action to enforce the Bank Secrecy Act. The Federal Reserve recently announced two enforcement actions involving violations of BSA.

Checking RESPA Answers

05/01/2002

Filling out the Good Faith Estimate and the HUD-1s is a lot like math exercises in elementary school.

BSA Audit Requirements

04/01/2002

Are banks required to have independent auditing of their Bank Secrecy Policy and files? If so, what should the audit consist of?

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Most Popular Compliance Content

Adding Owners CDs

01/29/2023

We have a CD that the customer wants to add a joint owner to in mid-term of the CD. I am thinking we should issue in lieu of since we are technically changing ownership. Others think we should just re-write the CD adding the joint owner while keeping everything else the same. What is your recommendation and why?

Freezing Future Deposits Upon Notice

01/29/2023

If an account doesn't have the entire amount specified in a "Notice of Freeze" and in this case it is from the Florida Department of Revenue, do we hold just what is in the account the day we receive the notice, or do we place a hold on the account for the entire amount of the notice thereby holding all future deposits up to the hold amount? (The Florida DOR collects taxes and child support.)

Joint Owner Dies - New Account Required?

01/29/2023

The bank has a joint checking account, husband and wife. The wife recently passed away and my husband would like to add his two children to the account. The customer thought it would be a simple process of providing a death certificate but the new accounts person said they need to open a new checking account. What is acceptable or required in a case like this to have the father and kids on one account?

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