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Latest Compliance - Operations Topics

TIL: Counting The Days

10/28/2002

The question always comes up for the early TIL as to how to count the three days. Everything says "within three days". Do you count the day of signing? Can you clarify?

Authorized Signer's Account Rights

09/02/2002

On an individual account for a son where the mother is an authorized signer what rights does the mother have on the account. My concern is that the son is going to war but does not want to make the mother a joint owner, with GLBA what in mind can the authorized signer receive statements, balance, information, etc.?

HUD's Proposed Revisions To The GFE

08/01/2002

HUD has published a proposal to make significant changes to the Good Faith Estimate that lenders issue within three days of taking an application. HUD calls this a "simplification" of the GFE.

Safe Deposit Box Liability

05/20/2002

I have been hearing about bank's liability for boxes when there is no disclosure about boxes not being insured by the FDIC or the institution?

Required Level Of Detail On the GFE/HUD1A

05/06/2002

My bank charges an application fee for closedend home equity loans, which covers all closing costs, including credit report, flood determination, title search, appraisal, and mortgage recording fees. Currently we disclose each of these thirdparty fees as P.O.C. and the applicable amount on the GFE and HUD1A. Another local bank uses a similar method of one fee to cover all closing costs. However, they only disclose the one fee on the GFE and HUD1A, with no references to fees paid to thirdparty service providers. Needless to say, our loan operations would prefer to follow this local bank's example. I believe we should continue our current practice, but I'm having some trouble finding clear regulatory wording to support my opinion. Section 3500.7(a)(2) refers to "no cost" loans, but our loans do have an application fee. Could I have your opinion on how our situation should be disclosed and also a regulatory reference to back that up?

Conducting an eBanking Audit

04/01/2002

Where's a good source for obtaining the basic knowledge needed for a novice to conduct an audit for the areas electronic banking and Internet banking?

Online Banker Training

02/11/2002

Are there any online banking courses that you reccomend? I am looking for a site the offers Rules and Regs training as well as soft skills. I would like to roll this online training out to all of our branches in Texas.

Cost/Benefit Analysis

02/01/2002

The concept is not new. It is familiar to almost everyone. A cost benefit analysis lays the foundation for deciding whether doing something is a good idea.

Compliance Training Requirements

01/07/2002

I work in a small bank and our compliance officer is no longer with us, is there a list of compliance training that we are required to do each year with our employees. I am getting into the compliance end of operations and need some guidence till I can get some training.

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Reportable SAR Amounts

03/19/2023

When filing SARs, for the total amount of reported activity would you include both incoming and outgoing transactions when it's the same funds? Example: Customer received an unusual wire for $50,000 and withdrew the funds in a structured manner. Would the total amount reported be $50,000 or $100,000?

P2P Claim, No Agreement with Vendor

03/19/2023

I have a Reg E Section 1005.14(a) question. If a consumer is disputing a charge that originated as an ACH from a P2P or other fintech and we do not have an agreement with the P2P or other fintech, can we as a financial institution direct the consumer to file their dispute with the P2P? Aren't they subject to Reg E Section 1005.14(a)?

When to do CDD on loan app

03/12/2023

For loans that take months from application to closing, at what point would you recommend collecting updated Customer Due Diligence? My initial thought is that as long as the loan had not closed, we can rely on the information from the previous 90 days, but would want to verify/update after that period, and I am having difficulty finding guidance on specific timing.

Basic steps for Reg E claims

03/12/2023

Must we go through the formalities of an investigation and document what we’ve done such as paying provisional credit on claims that were made timely?

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