Most Popular Compliance Content
Old account, New Account Hold
08/13/2023
If a credit union allows a member to establish a new transaction account after they pay back the amount owed from a closed, charged off account, would the newly established account be subject to Reg CC's new account definition? This would mean applicable checks deposited into that account to would be subject to new account holds. Could we determine that the member's actions causing the the charge-off means they forfeit the benefit of the previous account for Reg CC, and this newly opened account would be a "new account" holds under Reg CC, or would this be a misapplication of Reg CC's new account exception?
Oral Disputes Allowed
08/06/2023
Are financial institutions required to have a cardholder sign a dispute letter when filing a Reg E dispute on a debit card, or can a dispute be filed verbally and with no signature?
Risk assessments, controls, templates
08/06/2023
When you look at risk assessment templates, do you typically see inherent risk with granular controls for each? Or in the alternative are you seeing a shift to stating the inherent risk with an overall residual risk statement, and less granular controls narrative?
Can a lender be held liable for third-party appraisal valuations?
08/06/2023
Can a lender be held liable for third-party appraisal valuations?
What is a Reconsideration of Value (ROV)?
08/06/2023
What is a Reconsideration of Value (ROV)?