03/01/2002
Compliance is scattered across a lot of regulations. There are Reg Z and RESPA governing when and how to give applicants information about a loan.
03/01/2002
It used to be that when credit was denied, all you had to do was follow the rule in Regulation B's 202.9(f) which stated that you may
02/11/2002
Mortgage BankingAdverse Action Prequalification (inquiry) process (no written application) The lender obtains credit information from the consumer, as well as pulls a credit report. If, based on credit information, the consumer can not be offered credit at this time (for example, because of a bankruptcy) and is counseled that once the bankruptcy is cleared up they are encouraged (never discouraged) to return and the mortgage divison would reevaluate, would this constitute a denial and require adverse action?
02/04/2002
When we close a loan on the mortgage side we charge a $30 credit report fee. The actual fees are between $16.50 and $50. We averaged our actual costs and came up with $30; therefore, we are charging more for some customers and less for others.My question is is this practice permissable or do we have to charge actual costs.
02/04/2002
Is the only $$ penalty for pulling an unauthorized credit report $1000?
02/01/2002
Question: When we turn down an employment applicant because of information in their credit report, is there a time limit by which we have to send the applicant an adverse action no
01/07/2002
I recently saw a <a href="http://www.bankersonline.com/articles/v05n13/v05n13a7.html">question and answer</a> on BOL regarding adverse action letters to all individuals applying for credit. What if your prospective borrower is a business? (1) is an adverse action letter required and (2) if so, is a letter required to go to all owners associated with the business? Taking it a step further, if individuals apply for a business loan, is an adverse action letter required in that situation?
12/03/2001
We have a customer that opened a safe deposit box with our bank. Two months later he was arrested in another state for armed robbery. No other details.The rental was past due and we sent a certified letter to his last knowaddress. Rent was past due 5 years. Had not heard anything from customerfrom 1993 until this October. He attempted to reclaim the items from thedrilled box. All identification had expired (he had been in prison all thattime). We refused since all identification was expired and we had no proofit was him. He has now contacted an attorney and is demanding the contents.During the course of talking with the branch in trying to identify theperson, a copy of the contents was sent to my attention. Should we file aSAR since we know he served time for armed robbery and the contents arenumerous pieces of jewelry (Rolex watches, loose diamonds, diamond pendants,12 rings, etc.). This is a new one for me.
10/01/2001
One of the most common questions asked by new compliance officers is "what, exactly, is compliance?" No-one seems to have a clear, definitive answer to this - particularly not the management that m
08/01/2001
Hard on the heels of the FRB's interim rules on electronic disclosures comes guidance from the OCC on Weblinks.