Most Popular Compliance Content
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.
Signing a consent order
01/29/2017
Is a financial institution required to sign a consent order?
AAN on New Account
01/29/2017
Do we give an adverse action notices when we turn down an account?
Declaration Page Evidencing Coverage (Flood Rules)
01/29/2017
We have a no cashout refinance where property is in a flood zone. The way I read the flood rules, we still need a declaration page evidencing coverage and then during our ongoing monitoring of the property, we can then accept a notice of insurance coverage at that point. Is this correct?
E-Sign Compliance for Delivery of Appraisals
01/29/2017
In my search for guidance on e-Sign compliance for delivery of appraisals (Reg B) and Closing Disclosures (Reg Z) there seems to be a difference in what is recommended for Reg B & Reg Z. All the guidance on delivery of the closing disclosure states that a read or delivery receipt is not a recommended method of documenting proof of the date delivery occurred. However, guidance on Reg B delivery date of the appraisal tends to lean the other way and regarding a read/delivery receipt. In fact the commentary 1002.14(a)(4)(I) even states ... “Delivery occurs three business days after mailing or delivering copies... or when evidence indicates actual receipt by the applicant, whichever is earlier". With the commentary in mind is it necessary for us to get a confirmation e-mail to document the actual date of delivery of the appraisal or can we simply apply the guidance from the commentary and rest on the delivery occurred three business days after xmailing whether snail or electronic mail?