03/14/2011
Loan originally for the purpose of "finish construction on Son's home." Processed as a unsecured consumer line of credit. Can purpose be changed to commercial line of credit using the same loan number with all new documents referencing commercial purpose?
05/18/2009
How to Implement Risk-Based OFAC Monitoring Practices
Five steps to risk assessment; ten practices for monitoring
by Timothy R. White, CAMS
07/07/2008
With regard to a refinance under HMDA guidelines, when extending a current obligation with a new promissory note, but keeping the same note number is it HMDA reportable? I'm not sure how to interpret the phrase "satisfies and replaces and existing obligation."
03/27/2006
For Reg O under 215.8 record keeping for insiders, must we keep information on immediate family members, including spouses, minor children, and adult children living in the insiders home? Do we have to track or report this information?
01/23/2006
At our bank we have to do screen prints of when we do OFAC checks. How long do you advise that we hold these copies for?
05/02/2005
Is the bank required to have 2 forms of identification to open an account? Our Compliance Officer says it is the legal requirement of the Patriot Act, however I cannot find where it is required, only recommended.
10/01/2004
One of the FACT Act's new requirements is that creditors dispose of information obtained in a credit report in a timely fashion.
06/01/2003
The rules are out and the initial shock wave is over. No more excuses. It is time to get serious about building a Customer Identification Program.
Coverage
07/01/2002
We are approaching the $250 M asset size. What should our committee be preparing for once we cross over the $250MM Total Asset line?
12/01/2001
As is the case with almost any change or development, the events of September 11 have brought us more compliance.