Most Popular Compliance Content
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?
Retention of Physical Deposit Hold Notices-Reg CC
02/05/2017
What is your view on retention of the physical deposit hold notices to meet Reg CC retention requirements? We recently converted our core system and have the opportunity to electronically record data used to populate deposit hold notices rather than retaining the physical forms.The data will be in the form of a report rather than a customer view of the notice. Parameters are set in the system for hold types, hold days, and makes consideration for multiple hold scenarios such as large deposit hold for amount over $5,000, two day availability for $4,800, and next day for $200.There is also a required field for facts to support reasonable cause holds when confidential information is selected.
Notification if Lapse in Coverage Occurs (Flood)
02/05/2017
When there is a mortgage on a non-residential condo unit and the property requires flood insurance which is provided by the condo association, what is the best practice for the mortgagee on the unit so as to be notified if a lapse in coverage occurs? Our borrower has the inside of the unit covered for flood, but the condo association is not otherwise providing us with information on the common areas its policy covers.