Most Popular Compliance Content
Mitigating UDAAP risk
04/23/2017
Since UDAAP could occur anywhere, how do I prevent UDAAP occurrences?
Additional Funds Home Improvement-HMDA?
04/23/2017
In 2015 we reported this commercial loan as a Home Improvement loan on the LAR. The loan was commercial non-revolving line of credit for $50,000 that matures on 11/1/2016. On 5/15/2016 the borrower came back for an additional $30,000 to be added to this loan as the improvements are not complete. The additional funds paid off a non-dwelling secured loan, a small advance to the borrower, and the rest remains available on the non-revolving line of credit. None of the new funds satisfied any dwelling secured loans. In most cases when a borrower requests additional funds, we pay off the existing loan and book a new loan for the total of the old loan + the new amount request. Thus, it is always reported for HMDA as a home improvement as loans that are for both refi + home improvement = home improvement. In this case, being this is a commercial loan, the lender did not pay off the existing dwelling secure loan. We just added an additional $30,000 to the line of credit. Because we didn’t “satisfy” any dwelling secured loans, am I correct that this is not reportable for HDMA and is technically considered a Commercial Modification. Is this the correct interpretation of this loan? If any of the additional funds paid off/satisfied another dwelling secured loan, would this be considered HMDA reportable as either a refinance or home improvement loan? If so, is the entire loan amount reportable or just the increase?
Methodology of BSA Audit Quality Control
04/23/2017
I need to find out the methodology of BSA audit quality control. Is there a check list to ensure my audit firm is doing a good audit job? (basically evaluate the quality of audit, including scope, procedures and work papers).
OFAC responsibilities
04/23/2017
Our bank has deposit accounts for small grocery stores that offer transmittal services through companies such as MoneyGram. The grocery stores deposit their transmittal cash intake, then the big transmitter company debits the funds in bulk via ACH. In that situation, what are our OFAC responsibilities?
Revoked ACH authorization
04/23/2017
If a consumer customer calls us and complains that although he revoked his authorization with a company transactions have continued to post. Despite his complaint, the customer is unwilling to complete a written statement of unauthorized debit Can we just close the investigation and refuse to give the consumer his money back?