08/01/2002
The Federal Reserve Board has issued final HMDA rules for 2003 and for 2004. The expanded and much more complicated Loan Application Register ("LAR") comes into use at the beginning of 2004.
07/15/2002
I noted on your Roadmap that you indicated a transaction subject to RA9, with security interested perfected under old A9, perfected by filing, in the correct state, with the correct filing, should be continued prior to the normal lapse date by an initial financing statement. I was under the impression that a correctly filed security interest subject to a UCC1 filing under old A9 that meets all the requirements of RA9 should be continued by virtue of a UCC-3 continuation within the window period prior to the normal lapse date, not by an initial filing statement. Please clarify the need for an initial filing statement. Up to this point, I had understood that the initial filing statement was the means to maintain your lien position at the same time you were "correcting" or bringing into compliance with RA9 a filing not meeting the requirements of RA9, but for which you had been perfected under prior A9.
07/01/2002
Is there a simplified summary of the current, pending HOEPA changes/regulations, pertinent to a mortgage nondepository lender?
03/11/2002
What are the upcoming changes on Regulation C HMDA.
03/04/2002
In Section <a href="http://www.bankersonline.com/regs/215/2155.html">215.5 (c) 13</a>, the regulation is a little confusing and I was hoping that someone may have questioned this before. This involves loans from member banks to our executive officers. It mainly starts with <a href="http://www.bankersonline.com/regs/215/2159.html">12 CFR 215.9</a>. It then references section <a href="http://www.bankersonline.com/regs/215/2155.html">12 CFR 215.5(c) 13</a>.My question is if the extension of credit is:(1) In any amount to finance the education of the executive officer's children;(2) In any amount to finance or refinance the purchase, construction, maintenance, or improvement of a residence of the executive officer provided it is secured by a first lien and the executive owns the residence.Is the executive officer required to disclose this information to the board of directors within 10 days as required for any other credit over $100,000?I have read this section over and I am not clear on whether the executive is to report or not report.
02/01/2002
After several years of regulatory review and one year of dealing with special predatory lending considerations, the Board of Governors of the Federal Reserve System has issued changes to HMDA's Reg
02/01/2002
Documenting a loan is work. You know what is happening so why take the time to write it down when there are applicants to be helped?
12/03/2001
We have a customer that opened a safe deposit box with our bank. Two months later he was arrested in another state for armed robbery. No other details.The rental was past due and we sent a certified letter to his last knowaddress. Rent was past due 5 years. Had not heard anything from customerfrom 1993 until this October. He attempted to reclaim the items from thedrilled box. All identification had expired (he had been in prison all thattime). We refused since all identification was expired and we had no proofit was him. He has now contacted an attorney and is demanding the contents.During the course of talking with the branch in trying to identify theperson, a copy of the contents was sent to my attention. Should we file aSAR since we know he served time for armed robbery and the contents arenumerous pieces of jewelry (Rolex watches, loose diamonds, diamond pendants,12 rings, etc.). This is a new one for me.
11/01/1999
Question: Our examiner told us that when we are making a mortgage loan that is in a second lien position, our Good Faith Estimate and the HUD-1A should include the cost of items such as haza
12/01/1998
Question: If a home equity line of credit will be in first lien position, do we have to give the servicing transfer notice to the customer?