12/15/2014
An employee of the loan department received her real estate license without consultation or approval from Management. The licensing status is currently active. We understand there are implications regarding conflicts of interest, HR policy issues, and independence issues related to any duties associated with real estate lending. However, there are two questions related RESPA and Reg Z.
Question 1.- Does sharing an employee with a real estate agency now constitute an affiliated business relationship requiring the Affiliated Business Disclosure?
Question 2. How does this impact calculations of points and fees for HOEPA loans? Do we include commissions into the point and fee calculations based on them being paid to a third party?
09/08/2014
What is required for vacations by the FDIC?
01/10/2011
What is a "security committee"? We already have BSA, Compliance, Human Resources, Audit and Executive Committees.
03/31/2008
I plan to include a recommendation in my annual report to change the current reporting structure for the Security Officer. Presently, I report to the VP of Retail Operations. I am seeking references to cite that advise the bank security reporting structure should be in other areas such a finance, risk, administration, but not through retail because of the apparent potential for downward influences and the need for independence.
07/01/2005
On July 30, 2002 the Sarbanes-Oxley Act (SOX) was signed into law.
07/01/2005
04/01/2005
The role of the financial institution's Security Officer is different from any other industry. Banking is the most regulated industry in the United States.
11/01/2004
The First Problem: Appointment
06/21/2004
Does any regulation require us to have our policies addressing regulations, in whole or a summary, in the Human Resources manual?
07/07/2003
What procedures should be followed in the case of missing travelers checks? We have our internal auditors on the case now. What steps should the compliance officer take and is there anything he/she needs to do or will the security officer have most of the responsibility?