Sample Copy of Due Demand Clause for Reg O
04/02/2012
Do you have a sample copy of the due demand clause for Reg O? We have FDIC examinations and run a good bank, but they say we should have an executive officer sign the due demand clause.
Linda Westfall
Bio:
Linda Westfall is Excecutive Vice President of McCormack and Associates, inc., a company offering management solutions for the financial service industry.
Linda has 33 years of banking experience, and degrees in accounting and computer science. She worked in community banks for nine years and has been a consultant with MAI for 24 years. Her banking experience includes:
- Internal Audits
- Directors Examinations
- Compliance Audits
- In house compliance training sessions
- IT Audits
Linda received the Certified Bank Auditor designation in 1991 and the Certified Regulatory Compliance Manager designation in 1994.
Areas of Expertise:
Audit Services
Compliance Audits
Compliance Review
Fair Lending
HMDA Analysis
Contact info:
You may contact Linda at: linda@mccorm.com or visit their Web site at http://www.mccorm.com
Questions Answered
Difference b/w Interest Bearing Checking and NOW
03/19/2012
Would you please explain the difference between an interest bearing checking and a NOW account? Can businesses now have NOW accounts?
Documents that Require MLO's Unique Identifier
11/28/2011
We are receiving conflicting information on what documents the MLO's unique identifier has to be on. We have it on our applications but are being told that it needs to be on all correspondence, i.e., GFE, TIL, business cards as well as added to the MLO's email signature. Can you give us some guidance on this?
Intent to Proceed w/Mortgage Loan-In Writing?
10/17/2011
Is it necessary to document the borrower's intent to proceed with a mortgage loan in writing? Can you mark the intent once it is provided verbally?
Reg Z Disclosures for Private Education Loans
08/22/2011
Are we subject to Reg Z disclosures for Private Education Loans if we are paying off an existing student loan?
Looking at Accounts Individually "Protected Funds"
08/15/2011
I attended the 2011 webinar, "New Requirements for Identifying Exempt Funds When Processing Garnishments: Final Regulations." Do we look at each account individually? A savings account has no "protected funds" going into it, however, the funds are from a checking account that is "protected." Does this matter or do I just take the savings account and not look back?
Appraisal Policy "3 Days Prior" a Requirement?
06/20/2011
In a recent update for an Appraisal Policy template it was stated "The applicant will be provided a copy of the appraisal report promptly upon completion at no extra cost to the borrower, and in any event no less than three days prior to the closing of the loan". Is the three days prior a requirement of regulators?
Adverse Action Notice for FICO Score
06/20/2011
Is an Adverse Action Notice required when a credit report is pulled and the FICO score is not sufficient for the program desired?
HMDA and Primary Dwellings
05/16/2011
A borrower owns his primary dwelling free and clear. The borrower wants to take cash out to purchase another dwelling using only his primary dwelling as collateral. Is this loan HMDA reportable?
IRS Levies and Garnishment Rules
05/16/2011
Is an IRS Levy considered a Garnishment by the United States, or is a Writ of Garnishment by the United States simply when the US is the creditor? In other words, do IRS levies fall under the new rule?