11/18/2002
Our bank is seriously considering NOT using a TINSSN/EIN on periodic bank statements. It is felt this could help deter ID Theft and help with privacy issues? Could there be other regulatory ramifications if we did in fact not use the TIN on statements?
11/11/2002
I know that as of October, HMDA requires us to use 2000 Census data as opposed to the 1990 Census data. Does CRA also require us to use 2000 Census data?
11/01/2002
Meeting for the third time this year, the Fed's Consumer Advisory Council made identity theft its leading topic.
09/02/2002
Are there any available APY calculation tools other than the one the OCC has? We have some savings statements that are mailed semiannually and the OCC calculator does not allow entering that number of daily balances.
09/02/2002
<a href="http://www.bankersonline.com/regs/202/202.html">Regulation B </a>requires a copy of the appraisal report be provided to every loan applicant when the proposed loan is to be secured by a one to four family unit residential structure and an appraisal of the security is made during the loan process. If the appraisal is an internal appraisal where the tax card value of the property is used to determine value, does the bank have the obligation to provide the customer a copy of the internal bank appraisal along with the tax card that was used to determine value?
09/02/2002
On an individual account for a son where the mother is an authorized signer what rights does the mother have on the account. My concern is that the son is going to war but does not want to make the mother a joint owner, with GLBA what in mind can the authorized signer receive statements, balance, information, etc.?
08/12/2002
Are there any available APY calculation tools other than the one the OCC has? We have some savings statements that are mailed semiannually and the OCC calculator does not allow entering that number of daily balances.
07/15/2002
The FDIC recently completed a compliance examination at our bank. TheCompliance Report of Examination identified significant violations ofRESPA. In the first violation the bank was cited for not detailing thenames, addresses, and telephone numbers of each lender-designatedservice, [Section 3500.7(e)(1)(iii)] and for not describing the natureof any relationship between each and the bank [Section3500.7(e)(1)(ii). In the second violation, the bank was cited forproviding mortgage servicing disclosure statements that did notdisplay the bank's servicing transfer record for the most recent threecalendar years [Section 3500.21(b)(3)(ii)]. Finally, in the thirdviolation, the bank was cited for having five mortgages that containedGood Faith Estimates and HUD-1 or HUD-1A statements that did notreflect an estimate for hazard insurance.I am new to the compliance arena and I have been assigned the task ofcorrecting these violations. Since these mortgage loans are already onthe books, should the bank issue "correct" Good Faith Estimates,Servicing Disclosure Statements, and HUD-1 or HUD-1A's that reflectestimates for hazard insurance? Or should the bank take note of theviolations and not make any corrections because this problem is akinto "closing the barn door after the horse has already left"? Anyrecommendations that you can offer to correct these violations iswelcomed!
06/03/2002
For Reg P purposes, is it ok to send out annual disclosures as a statement stuffer (provided you meet the definition of "clear and conspicuous") and deliver it to all customers?
06/03/2002
When opening a POD or ITF account is it necessary to include the name of the beneficiary on the system or is it sufficient just to have the beneficiary name on the supporting documentation, i. e., signature card?