05/28/2007
Is the Truth in Lending Disclosure a mandatory early disclosure in addition to the Special Information booklet, Good Faith Estimate and the Mortgage Servicing Disclosure?
05/21/2007
When reviewing our website, what are the main compliance issues we need to look for?
04/30/2007
What regulations should be considered as we write our Remote Capture policy (Check 21, Reg E, Reg CC, etc.)?
10/23/2006
Besides the annual privacy disclosure are there any other disclosures required to be provided to customers annually?
10/02/2006
In the past, we sent mortgage loan closing documents to the title company via the internet. We stopped this practice because we feel that without having a secured e-mail line, and without encrypting the data, we would be in violation of GLB. Same with sending our Good Faith Estimates, or other disclosures. We stopped sending via e-mail to customers because of GLB issues. Are we correct in that it would be a violation of GLB to send non-public financial information electronically over a non-secure line?
08/14/2006
In the past, we sent mortgage loan closing documents to the title company via the internet. We stopped this practice because we feel that without having a secured e-mail line, and without encrypting the data, we would be in violation of GLB. Same with sending our Good Faith Estimates, or other disclosures. We stopped sending via e-mail to customers because of GLB issues. Are we correct in that it would be a violation of GLB to send non-public financial information electronically over a non-secure line?
02/13/2006
We have recently had a difference of opinion on a mortgage loan closing at our bank. The situation is a young couple apply jointly for the purchase of a new home. They did not have the down payment, so the joint applicant parents put a second mortgage on their home as additional collateral. The parents are not on the note, or any other documents other than an appraisal on their property and signing a mortgage on their dwelling. Does Right of Rescission apply on the parents?
01/01/2006
The financial regulatory agencies have issued joint guidance on nontraditional mortgage products.
12/01/2005
The agencies have published new examination procedures for FCRA and the FACT Act.
11/07/2005
I'm new to the compliance area for a small community bank. I came from a larger national bank where compliance was handled from a compliance deptartment. My question is the following:In reviewing several loans recently where we granted a loan for the purchase of land with a one year term with P and I due at maturity, I found no GFE, preliminary disclosure, or SDS. Are they needed on this type of loan? We also took as additional security a certificate of deposit. The note is a promissory note and does not have a security clause in it. We have an assignment of deposit account in file but no separate security agreement for the CD. I say we need one the lender says no. Who is right?