Most Popular Compliance Content
HMDA - Recouping Home Improvement Costs
04/07/2008
If part of the proceeds of a refinance loan are to recoup home improvement costs would the purpose be home improvement?
Final TIL - PMI Tax Included?
04/07/2008
Is the PMI tax included in the payment stream on the final TIL?
Hand Delivery of Adverse Action Letters
04/07/2008
Can adverse action letters be given to the customer in person in lieu of mailing them?
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?