10/30/2016
What are the downsides of a “divide and conquer” approach to backlog scanning of loan files?
02/02/2015
How should a returned check be handled in the branch? Does the customer need to be notified in advance of the returned check before the funds are debited from their account?
07/08/2013
I have a customer who was a partial recipient of loan proceeds. He asked that his part be disbursed in several cashier's checks made payable to his son. The son then would come in and cash the checks separately. Some needed a CTR and some not. I'm trying to decide if this warrants the filing of a SAR on either the father, the son or both?
03/18/2013
If a bank sets aside monies as a reserve for future loan payments involving a loan secured with borrower's principal dwelling, does that reserve fall under the definition of points and fees; i.e. finance charges?
03/04/2013
Can I take a payment due on an individual's loan out of the LLC, where the individual is an authorized signer and member manager?
02/04/2013
We have a customer that deposited a check from a friend. The check was a convenience check on the friend's credit card account. Right now the issuing bank tells us that check has cleared. What will happen when the friend gets their credit card statement and they didn't actually write that check and it's fraud? What are the return time frames that credit card checks fall into?
06/11/2012
1) Can checks be cut on day of closing and held until the rescission period expires? 2) Do they need to be post dated? 3) Can the loan proceeds on a second loan to be used for the down payment on a first mortgage be issued via cashier's check to the bank with the first mortgage on the property, or does the check need to be issued to the customer?
08/15/2011
Is a bank permitted under Reg O to grant a home equity line of credit in excess of $100K to an Executive Officer? Keep in mind that our HELOCs are drawn upon by checks which eliminates the Bank's ability to approve the exact purpose of draws at loan closing.
06/13/2011
We place exception holds for large deposits. Some of our branches are only allowing the first $5000 that might include a special check that is under $5000. There is some confusion, can you help us determine if we are violating Reg CC exception hold policy? Example #1 A large deposit consists of a special check for $2100 and several local checks totaling $6300.00, total days deposit $8400.00. The special check $2100 is made available the next business day, $2900.00 of the local check is made available in two business days and the remaining $3400.00 of local check is made available in seven business days. Example #2 A large deposit consists of a special check for $2100.00 and several local checks totaling $6300.00, total days deposit $8400.00. The special check for $2100 is made available the next business day, $100.00 of local check is made available next business day, $4900 of local check is available in two business days and the remaining $1300.00of the local check in seven business days. Can you clarify which example complies with the regulation?
06/14/2010
Due to the amendment to Reg Z and the passage of the higher education loans, our bank has taken a stand that we will not do any loans for student loan purposes. We had a borrower apply for a loan for a summer masters program and we have denied it as "requested terms not offered." The customer wants to reapply for a personal loan for debt consolidation. With the prior knowledge of the student loan, would we be in compliance if we were to do a bill consolidation loan and direct the checks directly to creditors (i.e., credit cards)?