Updating the HUD Booklet for Revised URLA
01/30/2006
Since the URLA has been revised is the Bank required to update the HUD booklet dated June 1997?
Lucy Griffin
Bio:
Lucy is Editor of Compliance Action and President of Compliance Resources, Inc., a company offering compliance support and services to banks. She is also a Senior Associate of Paragon Compliance Group, a company dedicated to providing compliance training. She has more than twenty-five years of experience working with regulatory agencies and financial institutions. Her extensive work experience with regulatory agencies includes the Federal Home Loan Bank Board, the Board of Governors of the Federal Reserve System, and the Federal Trade Commission. As the manager of the Compliance Division of the American Bankers Association, she worked directly with several of the association's banker committees and with regulatory agencies to identify compliance priorities, and to produce resources and programs.
Areas of Expertise:
Compliance Action Newsletter
Compliance Consulting
Compliance Seminars
Training the Trainer Materials
Contact info:
You can reach Lucy via email at: griffin@bankersonline.com
Questions Answered
Updating Loan Policy to Reflect FACTA Changes
11/07/2005
I am in the process of updating my loan policy to reflect recent changes to FACTA and predatory lending. I was going to just add a general statement to the policy stating that we comply with the changes in the FACT Act. Should I elaborate more in my policy and do I need to outline the entire Act in my procedures? What recent changes that I may have missed that need to be added to adjusted to my policy?
Compliance Calendar
05/02/2005
Do you have access to a Compliance Calender or tickler list of sort as to when documents need to be filed, or regulations have a due date for specific issues? I hope you can help.
Can we avoid the FCRA optout for information from the application that is publicly available?
03/19/2005
If information that is outside the scope of 'transaction and experience' under FCRA is publicly available (i.e. telephone number, driver license info, other demographics we can purchase), can it be shared among affiliates without offering an FCRA optout?
Disclosures to Non-Borrowing Owners
09/20/2004
When a home equity loan is made to only one spouse, exactly what documents should the other spouse be required to sign?
Application of Rescission to Business HELOCs
08/02/2004
Does the 3-day right of rescission apply to business HELOCs (using one's primary residence as collateral)? I was under the impression that rescission only applied to consumer transactions.
Doing a Compliance Risk Assessment
08/02/2004
I have to do a compliance risk assessment for my credit union. I have never done this before. I don't know how to get started. Help!
Copy of ID in Loan File OK?
08/02/2004
In the past we would not retain a copy of an ID for a commercial loan or mortgage in the loan documentation folder. We recently received the following advice from counsel: "This is the new FDIC guidance on retaining copies of the license pursuant to the USA PATRIOT Act. It would clearly be permissible to retain copies provided that they are not used for an impermissible purpose. This rule would seem to apply to both residential and commercial." Should we feel comfortable with this interpretation?
Determining Joint App Intent Over the Phone
06/21/2004
Reg. B changes become mandatory April 15. How are banks going to implement the following requirement when an application is received via the phone or Internet: Section 202.7(d)(1) states that we are no longer to assume that the submission of joint financial information constitutes an application for joint credit. Furthermore, section .7(d)(1)-3 of the Commentary states, “A person’s intent to be a joint applicant must be evidenced at the time of application.” In the written application, it is easy to add the recommended verbiage, but it is a bit harder to document evidence of intent for applications received via the phone and the Internet.
Disclosing Tiered Prepayment Penalties
06/21/2004
We are going to offer a no-closing-cost mortgage product. We are going to have a 6-year tiered prepayment penalty. Do we have to disclose all of them on the TIL?