Most Popular Compliance Content
Prequal Disclosures Required?
03/24/2024
A broker sends a potential borrower to the bank. He wants to pre-qualify for a loan that will be a finished house in a builder's subdivision which is represented by the broker. The dwelling will not be finished for 6 - 12 months. The bank received the application from the broker and pre-qualifies (no pre-approval program) for a later date. There would not be any early disclosures at the type of the pre-qual, correct?
Business Loan Appraisal Availability
03/17/2024
I am commercial loan broker, I have applied my client for an SBA 7a Loan, and we are near closing. The appraisal report is done, but the banker with whom I communicate, said to me that the appraisal is only available after closing. Aren't they allowed to send it, or he is doing it on purpose so we don't go with another lender?
Which Address on Flood Policy
03/17/2024
Can the legal address be used on flood policy instead of the physical address? This issue has come up where the insurance company is refusing to change the address. We asked if we could use the legal address instead.
Lease or Sale of Equipment to Merchants
03/10/2024
What is the difference between renting, leasing, or selling equipment to customers for Merchant Capture (remote deposit devices)? Are there any rules/regulations related to leasing or renting this?
Address Changes on New Accounts
03/03/2024
We continue to have issues collecting customers current physical addresses when opening new accounts. Our frontline thinks they find loopholes in our policy, deviating from the intent of the policy, and they create larger problems. Is it permissible to have a policy or procedure in place for changing the address on a new account for a new customer within 30 days of the date opened? Say if a customer opens an account on the 10th and then comes in on 21st to change their address, do other banks have a policy to collect a proof of address at this time since it is a new account?