08/08/2011
May we put our personal e-mail address on our business cards that we hand out to our customers? We have been told that we can't do this for compliance reasons.
02/28/2011
My question is about collection of GMI for HMDA where we are providing both a 1st mortgage and simultaneous 2nd. Our mortgage dept. takes the app for the 1st, then sends a request to the consumer loan dept. for the 2nd. The consumer lender almost never has contact with the applicant. Are they required to collect the GMI again or can they use the GMI that was collected by the mortgage lender?
01/10/2011
What is a "security committee"? We already have BSA, Compliance, Human Resources, Audit and Executive Committees.
01/03/2011
Are directors required to receive annual training on Reg CC?
09/06/2010
Recently the Department of Labor came out with rules regarding mortgage loan officers. We currently have an employee whose primary job is in commercial lending. He also does some mortgage lending on the side. Would we have to evaluate his salary as a part of the new rules? Because he doesn't primarily work with mortgages, would he be exempt from this?
07/26/2010
Can you tell me what exactly are "Units of general local government" and "Units of state government" agencies for Regulation CC purposes?
05/03/2010
Our bank has a "Relay for Life" team and we will be doing several fundraisers to help raise funds for this. One fundraiser includes putting a picture of our three loan officers on separate containers. The one with the most money in it at the end will win the prize of a pie in the face. Customers and non-customers will be able to contribute to the loan officer of their choice. The pie thrower will be an employee of the bank. I just want to make sure we stay in compliance. Are we?
03/22/2010
I heard from a colleague that the FDIC is citing banks under Regulation CC (Section 229.16(c)(2)(ii)) for mailing case-by-case hold notices for deposits made in person by a customer. Apparently this was caught by the examiners in banks where their procedures require that large dollar checks deposited into customer accounts be placed in a bin for later review/hold determination by an Ops manager or where there is a secondary review of all hold notices prior to mailing. Purportedly, the FDIC has taken the stance that a case-by-case notice may only be mailed to the customer when the transaction was not done in person and that any references in Regulation CC and the commentary about mailing a notice refers only to those specific deposits which are not done in-person. This is not the way we or our compliance auditors have looked at this in the past, and we are curious to know how your group views this. What say you?
03/22/2010
Does Reg O govern the interest rates one can provide on deposit (DDA and SAV and CD) accounts? Other than related to overdrafts, does Reg O impact deposit accounts in any way?
01/04/2010
We have never charged a document preparation fee in the past, but are thinking of doing so in the future. What are the compliance guidelines that go along with a document preparation fee? Are there any disclosures involved?