12/01/2005
Question: I've got an issue with a 12-month revolving line of credit up for its second renewal.
10/01/2005
Flood hazard insurance has been with us for a long time. Unfortunately, we still don't seem to be getting it right. Civil money penalties are assessed all too often.
07/01/2005
Question: I've been working on procedures in the event a customer's sensitive information is compromised and just discovered your article on the ID Theft Response Program Proposal.
02/01/2005
The regulatory agencies, government agencies and banking associations in Washington are all currently very actively involved with the Bank Secrecy Act/Patriot Act/Anti-Money Laundering compliance i
06/07/2004
This is specifically for David Dickinson, please. Your "Distinguishing Between Renewal and Refinancing" article published on BOL 1/5/04 answers a specific question that we have been attempting to get a clarification on from FDIC (with no luck yet). However, discussions previously in BOL have indicated differently - stating that various FRB seminars have indicated "new note - reportable"; Mary Beth's article in June, 2003 indicated if there is a new note, it is HMDA reportable; your posting "HMDA - refinance vs renewal" 6/13/01 you indicated that the renewal of a HMDA loan with a new note is reportable; and Jack Holzknecht in his November seminar was explicit in his response to this question, indicating that "if there is a new note, it is HMDA reportable". Our situation is EXACTLY the same as the questions in the 1/5/04 "Distinguishing" article and you are saying it is not reportable. So, is the key "if we consider our renewal note as an extension agreement"what makes it non-reportable, or something else? I am really confused and we want to get it right, but we do a tremendous number of "renewals" of HMDA-covered loans and would like to not have to report them if we don't have to. Can you help clarify, please?
03/15/2004
When renewing a balloon loan, secured by a residence, and changing the rate from a fixed rate to variable rate, what disclosures are required?
02/23/2004
With respect to Flood force placement guidelines, is it 45 days prior to policy expiration that the letter goes out to the customer, or a reasonable time after expiration that the customer gets notified and then has 45 days after receiving this letter to provide coverage to us?
01/01/2004
2003 was a banner year for Civil Money Penalty (CMP) assessments relating to flood hazard insurance at banks across the nation.
12/01/2003
Is there a Real Estate Matrix that I can refer to, to see if I have all that I need in regards to compliance? Example: I have a Consumer Real Estate loan and it is a renewal with no new money. Purpose of Loan my worksheet says Renewal orginial purpose (0602) was to purchase and improve residence. temporary financing. So do I need a new application, collect HMDA, Good faith? This is where I am getting confused. We make a lot of Commerical Real Estate loans and some consumer R.E loans. My confusion comes in when we renew. So is there a tool out there that I can refer to to help me make the right decisions when it comes to exceptions?
09/15/2003
It is our understanding that 12 CFR 230 5(a)does not apply to Changein terms notices for time accounts. Also the definition of a fixed rate account in the definitions section of TruthinSavings does not apply to a fixed rate time account. If this is true, please explain the reference in the Commentary under 230.5 (b)5i which states that "If the change is initiated by the institution, the disclosures requirements of this paragraph apply. (Paragraph 230.5(a) applies if the change becomes effective prior to the maturity of the existing time account.) Why is the 230.5a (30 days notice for adverse changes for existing accounts) reference there, I did not think you could change any term in a CD until maturity. Please clarify and could you give me a good example of how this works.