03/04/2013
When training bank employees, what is the minimum training allowed? We are getting a new core this year and it is going to monopolize a lot of time training for it. We want to stay within the legal guidelines and maintain a curriculum, but need to streamline it for core training purposes.
03/04/2013
During a recent webinar it was stated that Trust and Estate Accounts do not require the same regulatory disclosures as retail accounts. It was even recommended that they be carried as commercial and not retail accounts. This was news to the bankers listening to the webinar. Is it true they do not require the same disclosures as other retail accounts?
03/04/2013
What are the consequences of providing Reg Z disclosures for a business purpose loan? Does that subject the loan to Reg Z?
03/04/2013
I have a loan that appears to be a HMDA reportable Refinance, but not sure because we are not able to verify that the loan we are paying off was dwelling secured. The loan being paid off is with another institution. Should we report as a refinance?
02/25/2013
We are making a 1st deed of trust loan to purchase a primary residence and a second deed of trust loan for renovations on a 12 month interest only loan (to be refinanced on permanent financing with same lender at maturity by adding 1st & 2nd together). Does RESPA & REG Z both apply...and if so, can you make a 12 month interest only loan if it is a HOEPA loan?
02/18/2013
A loan was denied (address was TBD). Is it HMDA reportable?
02/18/2013
If a customer applies for an institutional CD and the bank finds the application to be ineligible/incomplete/denied, does an adverse action letter need to be sent for a CD application?
02/18/2013
In a training last week it was brought to my attention on the new CTR form that it is requiring the ID collection of an entity. In the past this has never been the case and in the FFIEC manual it specifically refers to individuals. FinCEN has said that there is nothing new to the forms except the collection of the new fields. Not in any webinar or documents that we received from FinCEN said anything about identifying document collection of an entity for a CTR. The only thing I have seen regarding this is actually on the form from the help box in the ID field itself. Is this something we have to collect going forward?
02/11/2013
This is a follow up question to the Q&A regarding Issuing Provisional Credit-Customer Closed Deposit which appeared in the weekly BOL Q&As on December 31, 2012. We had the same question but the customer's account was closed by our BSA department due to suspicious account activity while a Reg E claim was being processed. How do we provide the provisional credit when we are no longer allowing the customer to use the account? We can reopen the account to post the credit, but the customer wouldn't have access to withdraw the money due to the BSA closure. If we send a check to the customer we would have no way of retrieving the money should our investigation determine that the customer was not entitled to the credit. We are trying to manage compliance risk with two regulations.
02/11/2013
A spouse dies on a jointly owned CD. Can the name of the deceased be removed and the CD continued to maturity? OR do you let it mature and then change the ownership? Is there a penalty for changing only the name due to the death?