Most Popular Compliance Content
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?
Responding to Exam
03/31/2024
Our bank received an MRA (Matter Requiring Attention) to establish a testing/audit program due to a vacancy in the internal audit position for some time. We've engaged an external audit firm to perform the audit function starting this year. This firm was already engaged prior to our examination. I've never assisted with a response to an MRA and am wondering what format and information should be provided. Can you please share any key components or advice with me on this topic?
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.
Military lending and major problems
03/24/2024
What’s the most severe penalty for a military lending violation you’ve seen?
Prequal Disclosures Required?
03/24/2024
A broker sends a potential borrower to the bank. He wants to pre-qualify for a loan that will be a finished house in a builder's subdivision which is represented by the broker. The dwelling will not be finished for 6 - 12 months. The bank received the application from the broker and pre-qualifies (no pre-approval program) for a later date. There would not be any early disclosures at the type of the pre-qual, correct?