Most Popular Compliance Content
Wire Transfers w/o INC, LLC, CORP Included (Risks)
02/12/2017
We have been receiving several incoming wires sent to the beneficiary name (business account) without the INC, LLC, CORP included. Will this cause an issue or will it apply to any risks that we should be aware of at this point?
List of High Risk Customers Regulation (AML/BSA)
02/12/2017
What bank regulation is it that requires them to develop a list of high risk customers? OFAC?
Reg CC Extended Hold Notices
02/12/2017
Our front line staff creates the hold notice and then sends to the Fraud Dept to review and put on the system. Often times the front line does the Hold Notice Wrong. If we change the Hold Notice we send the customer a new one. If we decide the hold is not necessary are we required to send notification to the customer informing them their funds are available sooner then we originally informed them?
NMLS # Required on GFE? (SAFE ACT/Reg Z)
02/12/2017
I'm the internal auditor and reviewing compliance with SAFE Act and Reg Z for including unique identifier on loan documents. We originate our reverse mortgages through two investors. The documents are produced through the investor website. Does the NMLS # have to be on the GFE? I'm not seeing it on the GFE for either of our investors. What disclosure documents exactly is it required? (they have on the note, mortgage, application)
Adverse action reasons
02/05/2017
In regards to the check box options on an adverse action notice, as a commercial lender, I would like to add “Length of time in business is too short” as we do deny credit to many newly established companies (per our credit policy). So my question is this: Can I create my own reason or is there a specific set of reasons that I need to adhere to? Where does ‘length of time in business too short’ or verbiage to that effect fit on an adverse action notice?