Most Popular Compliance Content
Relocating Contents of Safe Deposit Boxes (SCRA)
02/05/2017
We are closing a branch and there are safe deposit boxes that are protected under the SCRA. We're thinking it's okay to drill the boxes and relocate the contents to another safe deposit box at another branch. Would you agree that this is okay to do?
Limitation for Loans Not Contracted Under UCCC?
02/05/2017
Could you give me your thoughts? Most believe Remote Deposit of check images are subject to Reg CC mandates. I have observed on BOL that this is not the rule, but is a best practice?
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?
Reg B Rules on Providing Appraisals/Electronic
01/29/2017
My question is in regards to Regulation B, section 1002.14- Rules on providing appraisals. Section 1002.14 (a)(5) -- Copies in electronic form --states the copies required by 1002.14(a)(1) (waiver and appraisal) may be provided electronically with customer consent. It does not state anything about the disclosure. Can the disclosure be delivered electronically?