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
The Audit Committee just hired an internal auditor, and the auditor is an FTE on the bank's books. How do banks achieve independence, (besides the audit charter), when the internal auditor is an employee of the bank? Is it unreasonable that the internal auditor would be subject to employee policy (handbook)? Administratively, whom should the internal auditor report to and to what extent? The rules of internal auditor independence, (banks under $500 mill) are black and white, but don't seem practical in reality. The new auditor is a rookie and is very concerned that in some way he will be asked to do something in contrast to what he is reading and researching about the internal auditor. We are struggling to strike the balance.
02/11/2013
We currently have Home Equity Lines of Credit (open ended) that have floor rates of 6.00% and 7.00% and we would like to reduce these to our new floor rate of 4.25%. I know under Reg Z Section 226.5b (f) it states we can make a change that will unequivocally benefit the consumer throughout the remainder of the plan. With that being said what type of documentation and disclosures must be given in order to stay in compliance with the regulators and terms of the loan? We want to ensure that if we do a modification agreement on the HELOC we do not need to redisclose on the loan.