06/09/2003
We have accumulated many accounts that are "no address" accounts. These have accumulated due to the customer not keeping us notified of a new or forwarding address. At one time, most of the accounts were service charged over a period of time and closed on their own due to a zero balance. Since that time, we have merged our regular checking product into a product that doesn't have a monthly service fee, therefore, most of the accounts are no longer service charged and would stay at their current balance (63% of them have less than $50 on deposit) until the funds would be escheated. NOW... the question....we are exploring the opportunity of implementing a service fee for "no current address" accounts. Our initial discussion with compliance was that we could implement that fee to all future "no address accounts" but not to the existing ones since we couldn't truly "Notify" them of the adverse change. I want to wholeheartedly disagree with that since we did disclose at the time the customer opened the account that it was their responsibility to notify us of any address changes.
05/19/2003
I am compliance auditor of our bank. Recently when I audited our 2002 HMDALAR, I discovered in a number of cases that our HMDA reporter completed the Sex codes with a "1" to "A" and "2 to "CA"(male and female) and the Race code with a code other than the "6", "7" and "8"(Other, No information, and N/A) all in the absence of the monitoring information obtained directly or indirectly from the applicant/coapplicant. There is no evidence of the reporter having gone thru the process of obtaining the monitoring information, but rather he bases his judgement on the names and other personal information given on the loan documents. Can he do that? Instead, should be change those codes to "N/A" or "No Information"?
05/05/2003
I know a change was made, but do we have to "guess" race if the loan application is taken by phone or can it be marked unknown for HMDA purposes.
04/21/2003
We are having a discussion about preliminary disclosures on mortgages. Do preliminary disclosures have to be sent when an application is submitted or when an application is completed?
03/01/2003
The Federal Reserve has spoken. Monitoring data may only be collected under controlled circumstances and for purposes of self-analysis.
02/03/2003
Our bank established a web site and made Internet banking and Internet bill payment available to our customers. The web site initially did not offer the Internet banking and Internet bill payment, so no changes to our EFTA disclosures were necessary. The problem is that when these Internet services were added and made available for customers, I was not notifiedas the Compliance Officerfor my bank. Therefore, the EFTA disclosures do not have the Internet transfers and bill payment EFTs listed in our disclosures (nor the limitations for these transfers). What can we do about this problem? I thought that maybe we could mail updated disclosures to all the Internet customers (after we amend our current disclosures). Will this be enough to satisfy our regulator in that we made a good faith effort to correct the problem as soon as it was discovered.
02/03/2003
Do Reg Z advertising disclosure rules apply to advertisements placed in the office, such as a poster which can only be seen upon entering the facility? Is this considered indirect advertising to the consumer and does that affect the applicability of the rules?
02/03/2003
Beginning January 1, 2003, lenders must ask for the government monitoring information over the telephone when someone applies for a loan that is reportable for HMDA purposes. If the applicant refuses to provide the information when given the option, is the lender required to obtain this information by visual observation or surname if the applicant is approved? Or does the lender report it as "Not provided?"
02/01/2003
y Steve Cocheo, Banking Journal
How many compliance officers does it take to screw in a light bulb?Actually, we have no idea - and who cares, anyway? It's useless trivia.
02/01/2003
While you may not have wondered how many compliance officers it takes to replace a light bulb, chances are you wonder lots of other things about compliance in other banks - such as salary, budget,