Thank you for lending your expertise to the BankersOnline.com community.
12/12/2021
I am searching for a policy for the financing of boat docks/slips. Senior management is at odds with one another over whether it is prudent to require the real estate adjoining the dock or if the asset itself is marketable. One senior manager argues that the permit is the value in the asset? So we are looking for a sample policy on this, and any insights from those familiar with such loans.
10/03/2021
We are a small community bank with $250 million in assets. We have lost our compliance officer again. Unfortunately, we can't justify a full time position for this. Do you know if banks are outsourcing this function and if so, where do I look to find the firms who offer this service?
05/09/2021
Is it a requirement (Reg or Legal) to keep hard copies of Signature Cards with wet signatures?
05/09/2021
We are creating a rate sheet to be used by local Realtors. It will provide the current rates for several types of loan products. Under our in-house loan category, Marketing would like to list "Limited Time Offer" as one of the bullet points. I recommended they provide an expiration date. Marketing wants to show that as follows - "Limited Time Offer. May Expire Without Notice." Since UDAAP is governed by perception of the reader what are your thoughts, I am still leaning toward a hard expiration date. What is required, or commonly done?
04/18/2021
I have a personal construction only loan that we are increasing. How do I disclose the fees that are associated with the increase? Can the bank charge a processing fee? The rate and maturity date are not changing.
10/04/2020
Is there a matrix that shows training requirements for the different regulations? I know BSA is an annual event, but I'm looking for guidance on Reg O, Fair Lending, UDAAP, etc. and especially for the board of directors.
09/13/2020
Can a relationship manager be personally liable for flood damage?
03/23/2020
If the bank charges PMI and doesn't have a PMI insurance company that it has to pay can the bank truly collect the PMI? For example, if the bank had loans that didn't sell on the secondary market, and the insurance gets cancelled, can the bank still collect for the PMI?
03/15/2020
Our collateral consisting of 62 acres of farmland, a residence, a hog barn and a cattle barn appraised for $465,000 in 2017. It is owned by an Amish (full-time farm family) borrower. The land and livestock buildings account for $$395,000 of the overall value. The primary residence comprised $70,000. Our first mortgage loan made in 2017 was a business purpose loan. Now these borrowers want to refinance it to add an additional $80,000 remodel. Is this a still a business purpose loan, or will it be a consumer loan? The total loan balance after the new house addition will be $366,000.
02/23/2020
Can email notifications be sent for abandoned property? My understanding is that this is subject to what each state may require depending on the address the account holder is located. Some states require a written notice to be mailed. So if we meet E-SIGN requirements would that supersede state requirements? Would CAN-SPAM Act also need to be considered as not being in violation since it talks about "notification of a change in the recipient's standing or status"? I'm thinking this Act is more related for purposes of commercial electronic mail.