HMDA Reportable Loans?
04/14/2024
Are refinancings of second homes HMDA reportable?
You can reach Randy via email at: careyrandy@comcast.net
04/14/2024
Are refinancings of second homes HMDA reportable?
04/14/2024
If all of a lender's marketing is targeted outside the US, aside from marketing within its "claimed" assessment area, could the lender be subject to REMA redlining review? I've read guidance that implies marketing doesn't have to be a factor for a REMA redlining exam to be conducted... • "REMA...defines who and where you serve, and as such, is different from a defined Market Area..." • "Where the lender actually marketed and provided credit, and where it could reasonably be expected to have marketed and provided credit based on its distribution of loans and applications " • Redlining analysis will look at lending and level of services in majority-minority census tracts compared to peers, among other items.
04/07/2024
According to Reg E, if I need to reverse provisional credit from a customer and they do not have the funds in the account in the amount of the reversal, can I proceed even though it will leave the account in the negative? The customer has been notified verbally of the reversal and I will send the reversal letter via mail, but they have made no attempt to deposit the money to cover this. Can I proceed, regardless of if the funds are available and still be in compliance?
04/07/2024
If a bank has fraud on the banks official check account, who does the bank report that to? As we get notifications on other institutions fraud official checks we are unsure of how that information gets sent out.
04/07/2024
If a lender is cancelling the SBA guarantee on the existing SBA loan and converting that to a commercial loan, is it acceptable to pay off the existing SBA loan and simply create new commercial loan, or should we use a loan modification instead?
03/31/2024
Our bank received an MRA (Matter Requiring Attention) to establish a testing/audit program due to a vacancy in the internal audit position for some time. We've engaged an external audit firm to perform the audit function starting this year. This firm was already engaged prior to our examination. I've never assisted with a response to an MRA and am wondering what format and information should be provided. Can you please share any key components or advice with me on this topic?
03/31/2024
If a customer authorizes someone to use their card and gives them the PIN for a specific transaction, and that someone uses the card for additional transactions that were not authorized by the customer, is their any negligence by the customer for giving the card and PIN for the first authorized transaction? What are the requirements according to Reg E ?
03/31/2024
What are the pro's and con's of New Accounts completing various Resolutions when opening business accounts? I was advised by legal, that if we use ione, it needs to be board approved and we better know how to complete them accurately. If they are this binding or legal of a document, is it best to not use them? Our system generated resolutions are complicated and we are not completing them consistently.
03/31/2024
The Equity Originations line of business wants to start offering a cash bonus incentive for customers opening a new loan/credit line. The bank has offered cash bonuses on the deposit side for years, however never on the lending side. Under RESPA, I am aware that a cash bonus/incentive cannot be tied to a referral, but other than that I am struggling to find any regulatory constraints, guidance, or precedent. Any guidance would be appreciated.
03/24/2024
Is this correct? Surviving joint account owner(s) can continue to use a deposit account as normal. The decedent will need to be removed from any deposit account they are an owner of. We thought the account had to be closed and another one opened but I'm hearing conflicting opinions.