06/19/2022
Providing an entire loan file to an Executor
12/08/2019
I need to know in this scenario if a CTR is required for the husband?
The wife and husband come into the bank. The wife conducts a deposit to her personal (individual) account of $8,000 in cash. Then she conducts a
deposit into the joint account (with her and husband) for $2,600. In my mind a CTR only needs completed on the wife because the wife is benefiting
and conducted the $10,600 deposit. The husband did not conduct either transaction and is only benefiting from $2,600. Is my thinking correct?
If required, please explain why a CTR is needed for the husband. Also, if a CTR is needed for the husband, I would like for you to consider this same
scenario but without the husband present for the $8,000 deposit to the wife's account. When he enters the bank to make a $2,600 deposit to the
joint account and we tell him we need to complete a CTR, wouldn't we be breaching customer information to tell him it is because his wife made a
large cash deposit to her personal account early in the day?
12/08/2019
Are there any regulations concerning a Land Trust Department having access to retail banking documents in an institution?
10/28/2018
We have an account holder with a variety of small business loans.
He "paid" his business partner, who is not on any of the loans, with a piece of property in which we hold the lien. The business partner has recently asked that we sell him all outstanding notes. Do we face a privacy concern by letting the partner know loan balances, etc. or are we covered by mortgage servicing rules? I believe that we can just send the mortgagee a notice that his servicer will change and accept the note payoff from his partner. My CEO seems to think there might be a privacy concern. I appreciate your thoughts!
08/09/2015
The alternate delivery method for annual privacy notices requires the notice to be included "on" a statement, coupon book, notice, disclosure. However, some statement forms don't lend themselves to putting a message right on the statement. Instead, can we insert a notice with the statement that contains the required language, indicating that the privacy notice is available on our website?
02/23/2015
What regulations outline requirements for shredding of paper documents that are bank, or customer, consumer information?
03/04/2013
The Fair Credit Reporting Act requires that each applicant (assuming there is a co-applicant) receive an FCRA adverse action notice in the event of an adverse action. Assume that there is a joint application for an installment loan, not secured by real estate (auto loan for example). The loan is denied because after a review of the credit reports of both applicants, the primary applicant previously filed for bankruptcy and the co-applicant has delinquent obligations with creditors. Should each separate notice provided to the applicant and co-applicant only list the reasons specific to their own credit history? In other words, should the applicant's notice only reference the bankruptcy and the co-applicant's notice only reference the delinquent credit obligations? My reasoning for feeling this way is that 1. it protects the privacy of the applicant and co-applicant and 2. it will better inform the applicant and co-applicant of what specific reasons were used in their denial so that each individual may correct them in order to secure the credit in the future. I understand only one would need an ECOA notice but my concern comes specifically from FCRA notice requirements.
12/03/2012
When the collateral of a loan has been totaled is it a privacy issue for the bank to give a payoff to the insurance company without the customers consent?
11/28/2011
When a loan is made to an entity but is secured by the residence of one of the members, is it OK if the entity and/or other members also receive the home ownership counseling notice or does this notice have to only go to the homeowner?
08/15/2011
Do we have to/should we have our clients sign/acknowledge that they received a copy our our new Privacy Notice that went into effect 2010? My question stems from a recent FDIC exam.