10/06/2003
Our bank has an insurance company in-house.Do they have to comply with CIP rules? Insurance customers do not have to have a banking relationship and the two entities are owned by the same holding company. As we've read all the CIP documents there is no specific reference to insurance policies - just deposit and/or credit accounts and "banking relationships", but neither of those may apply in many of the insurance companies transactions. Thank you for any thoughts you could share on this topic.
09/02/2003
Can we combine the Patriot Act Disclosure with our Privacy Policy Disclosure?Our loan officers feel that we already load up our potential loan customers with too much up front paperwork and they want to place both disclosures on one page. Can we do this?
08/04/2003
When handing out Home Equity applications what disclosures should we give our customers to stay in compliance?
08/04/2003
Please help us resolve this dispute. The question is if a loan should be considered for consumer or commercial purpose for compliance with Regulation Z. The borrower is an individual acting as a builder for his son-in-law. He has previously built two homes for himself. His income, however, is not made as a builder. He works in an unrelated capacity. He is also not making a profit on the construction loan. I think Regulation Z would apply to this loan. Please help.
02/17/2003
Now that the National Flood Insurance Program has been reauthorized, what do we need to do?
02/03/2003
As a secured party, if I collect partial satisfaction of an obligation, may I still pursue a deficiency judgment?
02/03/2003
Can we impose a fee if a customer exceeds the transfers limitations on their money market account?
12/16/2002
We are financing a customer's real estate loan which will be paying off another institution. However, the loan we will be paying off is the initial construction loan for the home.Does rescission apply?
12/02/2002
Is it okay to have an authorized signer on a joint account?
11/18/2002
Does HOEPA apply to mobile home loans not secured by real estate?
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