Loans Denied Due to Criminal Subpoenas
02/06/2022
What can we put down as the reason for denial on the Adverse Action Notice, for loans denied due to criminal subpoenas? Can we select "Other" and specify "BSA concerns"?
02/06/2022
What can we put down as the reason for denial on the Adverse Action Notice, for loans denied due to criminal subpoenas? Can we select "Other" and specify "BSA concerns"?
08/02/2020
I have a question on the new Reg CC update, specifically, on the large check deposit. I have a customer depositing a out of town check made to himself in the amount of $106,000. How do I handle this? Example: 2-12-2020: Place a Large Deposit Exception hold on the check making $200 available 2-13-2020, $4,800 available 2-14-2020 & $101,000 available 2-24-2020. So would the new amounts be $225 available 2-13-2020 and $5,300 (to make a total available $5,525) available 2-24-2020 and the rest available 2-24-2020?
06/21/2020
Our bank has limited the number of overdrafts an employee may have in a rolling 11 month period. Management now would like to treat employee like other bank depositors and eliminate the limit. Are there any compliance concerns with this action? My initial comment was that employees of a bank should be held to a higher standard as the general public is entrusting their funds in the integrity of the bank's staff. Thoughts?
05/24/2020
Is a large bank required to send adverse action notices when a payment due date change or extension is denied for consumer loan products?
03/08/2020
I am a Realtor and a lender has ask me to participate in a Realtor partner referral program. They want me to refer and recommend other real estate agents to them. The Realtor partner receives leads from the lender, that is buyers that do not have an agent. No money is exchanged, and there is no pressure to send them my business. Is this a violation or not?
03/01/2020
Do the Private Education Loan disclosure requirements apply if we originate one loan to an employee to help them get caught up on past tuition so they may enroll in classes?
02/09/2020
Can a lender accept verbal telephone confirmation from an applicant of receipt of the 3-day closing disclosure?
02/02/2020
Our loan officers pull clients credit reports and input the information in our LOS. Not all six items that make up an application for a home loan have been provided. My question is, do we still send out a "Notice of Incompleteness" to the client if the only thing that was received in the loan file was the credit report and the loan has been in our system for 30 days with the property marked, "TBD?" The way I read Reg B is that you only send out the NOI once it is considered an application. So if these are not considered an application but you obtained credit, would we not have to send some sort of documentation/NOI because the score is good enough to move forward?
01/26/2020
I started in BSA a few years ago and I built an Enhance Due Diligence program for higher risk customers with monthly transaction review and then yearly comprehensive review of the business and its expected vs actual activity. At the time I found a really clear outline of expectations in the BSA Manual and now I can't find anything related to EDD at a all. Did this get removed? Anyone else experiencing this?
01/12/2020
Who should technically be doing a loan closing?