Most Popular Compliance Content
Avoiding Bankruptcy
04/28/2008
What can banks do to help small businesses avoid bankruptcy?
Lowering Rates on Existing Mortgages - Redisclose
04/28/2008
Due to the current rate environment, we have decided to lower some rates on existing mortgages. We are charging a flat fee of $200 and completing a change in terms agreement to show the new payment terms. Do we have to redisclose the APR and fee since we are changing the terms to benefit the consumer?
Sending 1098s
04/28/2008
Are we required to send 1098s on anything other than personal residence?
CD Rate Oral Inquiries - Quote APY First?
04/28/2008
During a recent audit it was noted that for CD rate oral inquiries some staff members were disclosing the interest rate before the annual percentage yield. I can't find anywhere in Reg DD that says you must quote the APY first. Is there something I am missing?
Flood Compliance & Master Certifications
04/28/2008
On construction starts to builders for multiple lots, is a master certification for flood determination within compliance? In my banking history in the residential construction lending area, banks historically used master certifications. Most banks use companies such as TransUnion settlement solution for flood certification. When ordering a master certification you send a legal description, plat and survey, plus the recorded plat and section. In my past experience with other banks this was fine. You keep the recorded plat in file along with the flood determination and the multiple lot (master certification) for documentation. I contacted TransUnion for further clarification and was told that this form of certification is used by multiple banks and is acceptable. I believe that the flood certification company is liable for correct flood determination. When the house is complete and sold to an individual, then it is the responsibility of the lending institution to order an individual flood determination. We are a young bank and wish to make sure we remain in compliance on flood determinations. Your expertise and input to this question is appreciated.