Most Popular Compliance Content
When in doubt, include the fee?
04/09/2017
We live by the axiom “When in doubt, include the fee in the finance charge.” Doesn't that protect us from violations?
Bank Responsible for Revoking OD Fees?
04/09/2017
We have a customer who signed & opted into ODP when he first opened the account in September. After the 45-day qualification period, it was found that his account was eligible for ODP so we activated the ODP on his account. A teller at his branch, however, took a request from him to revoke ODP on his account in late November. This was not relayed to the appropriate staff and the change did not get made on his account. His TV bill, which is an authorized monthly payment, came through on his account as a POS debit while he was already a couple dollars negative. It should've been declined due to NSF and him previously revoking ODP. We've since made the appropriate changes on his account to revoke ODP on his account and we've reversed all the fees he shouldn't have been charged, but the customer is saying he is not going to pay for it, and that the bank is responsible for it. My question is - is the bank responsible for it?
Verifying mortgages for HPML status
04/09/2017
I am auditing a bank and verifying consumer 1-4 family loans are not HPMLs. I am using the Closing Disclosure date and APR to perform my testing. Am I using the correct date and APR?
Pre-approval/Notice of Incompleteness/Denial (CD)
04/09/2017
Are mortgage lenders required to issue a credit decision (conditional approval or Pre-approval or notice of incompleteness or denial) on purchases and a commitment letter on refi's within 30 days of application? We have a purchase of new construction file that sat for 4 months while construction finished with no credit decision.
UDAAP avoidance starts with prep
04/09/2017
Do you have any advice about preparing for our next exam in light of the regulatory emphasis on UDAAP?