Most Popular Compliance Content
HMDA Reporting - Wholesale Lender
03/31/2008
I am a wholesale lender, do I need to report HMDA?
Tree Removal & HMDA Reporting
03/31/2008
Would tree removal from a property with a house on it be HMDA reportable?
HOAs & the USA Patriot Act
03/31/2008
An issue has arisen at my bank concerning the need for a signatory on a homeowners association account to submit his social security number. My bank's BSA Officer believes that he must do so. I am not so sure. This individual has no personal accounts with our bank, but is listed as a signatory on two accounts dealing with homeowner's associations. The person in question refuses to give his social security number. How are HOAs classified for purposes of the USA Patriot Act? It's my understanding that the HOA is the owner of the account. I know that the signatory situation was in the proposed rules, but not the final ones. I would appreciate it if someone could provide me with some guidance.
Gift Cards - Monetary Instruments?
03/31/2008
Are gift cards still not considered monetary instruments? Is this something that is coming in the future?
Security Officer Reporting Structure
03/31/2008
I plan to include a recommendation in my annual report to change the current reporting structure for the Security Officer. Presently, I report to the VP of Retail Operations. I am seeking references to cite that advise the bank security reporting structure should be in other areas such a finance, risk, administration, but not through retail because of the apparent potential for downward influences and the need for independence.