Most Popular Compliance Content
Will my bank be exempt from HMDA?
01/29/2017
We are not sure if we will be subject to HMDA in 2018. How do we determine this?
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?