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Latest Compliance - Reg. CC Topics

Reg CC and Large Loose Coin Deposits

06/02/2014

I would like any opinions or guidance from you regarding Reg. CC applicability to large, loose coin deposits. If a customer brings in multiple bags of coin, when are the funds considered deposited, and based on that, when must the funds be made available to the customer? From Reg. CC ( 229.2(h), 19(a)) it seems apparent that we need to provide availability by the next business day. However, bank branches do not maintain commercial coin counters to get this done. And we can't refuse legal U.S. tender, right? I imagine that banks are saying that the deposit has not actually occurred until the coin is counted (usually by a bank vendor/service), but I need to know the rationale behind that opinion.

Hold CC for Reason to Doubt Collectibility

03/31/2014

Can we put a hold on a cashiers check? Can we hold it for reason to doubt collectibility? If so do we have to allow $5000 to be available next day? What if it is under $5000?

Best Practice for Reg CC Notice of Hold

12/02/2013

Regarding Reg CC Holds, is it a better practice to have the notice of hold spell out the actual date that funds will be made available vs a statement like funds will be made available after 7 days?

FDIC lists common compliance problems

12/01/1997

The most frequently violated compliance requirements involve the Real Estate Settlement Procedures Act (Regulation X), a FDIC list revealed.

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Identifying "protected funds" in a joint account

07/28/2024

When we receive a garnishment order identifying a judgment debtor who has a joint account at our credit union, and there are federal benefits that have been direct deposited for both of the joint owners of the account, which of those direct deposits do we treat as “protected funds”?

Hazard insurance on TRID disclosures

07/14/2024

If I am refinancing a primary residence, do I need to include last year's insurance on the loan estimate and closing disclosure as a POC fee? Or can I just leave it off because insurance and taxes are accounted for on my Initial Escrow Disclosure?

Re-using a recent appraisal

07/07/2024

We have a business account that took out a construction loan 11 months ago on lot A. Our business customer just bought lot B (right beside lot A) and is planning to use the exact same floor plan as lot A for lot B for the construction. Since this appraisal was completed 11 months ago on a different address, would we have to get a new appraisal completed for lot B, or, since everything is the same besides the address (right next door with same floor plan not 1 year old) could we reuse the lot A appraisal for lot B? I am having trouble finding information about this in the regulation.

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