Most Popular Compliance Content
Business Identity Theft
03/31/2008
Is business identity theft becoming a problem?
Separate Banks, One Owner - Late Charge Procedures
03/31/2008
I have a client bank that has just purchased another institution. The two banks have been under the same holding company, but now will be the same bank. For purposes of late charges imposed, must both banks use the same late charge procedures as far as when they are imposed and how much or is it just a matter of disclosure, as long as two separate procedures are disclosed, two modes of implementation will be deemed acceptable?
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.