Most Popular Compliance Content
Reduction in a bank’s exceptions
01/29/2023
Why might a bank experience a reduction in exceptions?
State Law and HMDA Categories
01/22/2023
I have a general question about Texas Home Equity law and HMDA reporting. If under Texas law, a home equity loan is considered a refinancing or cash out refinancing regardless of whether the new loan satisfies an existing dwelling secured debt, can that be reported as a refinancing or cash out refinancing on the HMDA LAR? To my understanding, state law does not impact the reporting of loan purpose under HMDA rules. If a new loan does not satisfy an existing dwelling secured debt, should it be reported as refinancing or cash out refinancing? I’m specifically referring to the Texas A6 Home Equity loan product. Under Texas law, this product is always classified as refinancing or cash out refinancing regardless of any other definition of refinance.
Reg CC Holds on Treasury Checks
01/22/2023
Can a US Treasury check be placed on a funds availability hold and for how long?
Military lending and major problems
01/15/2023
What’s the most severe penalty for a military lending violation you’ve seen?
Reasons to Refuse a Foreign Account
01/15/2023
We have a customer (existing, but the current business is unrelated to the business in question) that maintains a business based in the UAE and wants to open a deposit relationship in the U.S. The customer is willing to register the business in Texas as a foreign entity, using the UAE address. Our policy states we do not open accounts for foreign business. We are a small bank with small infrastructure. I have a suspicion that this deposit account will be used as a shell company. How can I inform management that I do not recommend opening the account for what I deem a high-risk entity? Is there something I can cite as support?