03/04/2002
Borrower is a corporation with one shareholder. All business assets are pledged as collateral. Lender wants the spouse to also sign on loan docs, with the concern being that she may gain ownership of at least 1/2 assets should they divorce. Would asking her to sign be a violation of Reg B? If so, does the lender have a bona fide concern regarding assets or does the fact that the borrower is a coporation make this a non-issue? Flip side: What about if the borrower was a partnership or sole proprietorship and the spouse has no role in the affairs or function of the business? (e.g., farmer Bob who takes a loan secured by crops.) Lender wants to add wife to loan as a condition for the same reasons listed above. How should I advise my lender?
02/11/2002
Is there available an audit program to audit the bank protection act/security review.
12/01/2001
11/05/2001
I was researching information on BOL and came across an answer that you had given regarding Opening Procedures - one vs. two employees. We currently have a policy in place that requires two persons to open. The problem...our CFO arrives extremely early and opens by herself. She knows the policy and accepts responsibility for the fact that she is not following it. The other problem....during a recent audit we were cited for this. The auditors arrive early and thus saw her disregarding policy. I know in Banking that senior management always presents this problem but I need to address it. I really don't want to change our two person policy. The auditors recommended having each employee sign an acknowledgment of policy to be placed in their file. Do you have any other suggestions? We are a very small 2 branch organization in the country.
11/05/2001
I need to develop a security program and prepare a security report for the board of directors. I am looking for a sample or advice on what to do.
11/05/2001
11/05/2001
Where can I find information on reporting to Board of Directors on Security annually?
09/03/2001
Is the Bank Protection Act (BPA) still the leading authority for security at banking institutions?
08/06/2001
Are we required to notify our customers of possible computer intrusions? Where can I find regulatory information regarding intrusions or hacks and the notification of customers?
04/01/2001
The revised rules and regulations required by the Bank Protection Act have placed a greater responsibility on financial institutions, their boards of directors and their security officers/managers.