Most Popular Compliance Content
Flood Insurance Coverage Conundrum
04/21/2008
We have financed the construction of a six story condominium building that is located in a flood zone. Our borrower is a commercial entity and for our purpose, the project is a commercial development. Our borrower has obtained $250,000 of flood insurance coverage, however, we are requiring $500,000 which is the maximum available for commercial property through FEMA. The borrower's insurance company has been unable to increase the policy. The insurance company states that the building is residential in nature since the end result will be a condo building. The insurance agent has tried to convince the insurance company that it is really a commercial property and has been unsuccessful in this argument. Do you have any suggestions or solutions for our insurance conundrum?
HMDA - What Census Tract Info Do We Use?
04/14/2008
In regard to HMDA, if a personal residence is being used to improve another property what census tract information do we use? The collateral census information or the property on which the improvements are being done?
Eliminating Float a Regulatory Requirement?
04/14/2008
Due to the recent implementation of image cash letter transmissions at our financial institution, we have experienced an increase in our immediate funds availability. Have there been any changes to banking regulations that would require us to change our float tables and eliminate the two day or three day float, as it pertains to paying interest to our clients on these expedited available funds?
Reg B - Application Signed With a "Courtesy Title"
04/14/2008
If a member fills out an individual credit card application and signs it "Mrs. Ethel Jones", has the credit union violated Reg B by accepting a "courtesy title" that indicates the applicant's marital status, which cannot be considered on the application for unsecured credit?
Lowering Interest Rates on Existing Mortgages
04/14/2008
We are offering to lower the interest rates on existing mortgage loans for our good customers. Do we need a new disclosure signed by the customer?