Most Popular Compliance Content
HMDA Reportable Transaction Exclusions
12/22/2024
I actually referenced these as well which is what I used to support my interpretation; however, the other interpretation I heard the reason they said they got to that was following the citations along with the HMDA reportable transaction exclusions. So 12 CFR § 1002.104(b)(2) then if you go to the citation referenced there 12 CFR 1003.2(e) then go to the 1003.3 (C) referenced there. So looking at those exclusions it doesn’t mention anything in regards to if your bank is in an MSA or not but #11 references FI that have fewer than 25 loans. Hence, that being their reasoning that the only way non HMDA banks would exclude HMDA transactions was if they were non-HMDA due to loan volume. I’m not disagreeing with your answer because that was our interpretation as well but when following the citations that they used to come up with their interpretation and can see why they would maybe think that.”
Investigating a non-Reg E claim
12/22/2024
If a customer places an order online, but never receives their merchandise, do we have to investigate?
There are GAPS in your CMS and they involve lending!
12/15/2024
Do you think you have gaps in your fair lending and CRA program?
Bad data results in large fines!
12/15/2024
I heard there were three major HMDA CMPs, what caused them?
What you need to know about the changed closed-end reporting threshold
12/15/2024
My FI has never had HMDA issues before; why do I need this course?