|
CRA
|
|
Does the FBAA map need to state that it's a "Facility-Based Assessment Area"? Our system has not been updated to state that. It only states Assessment Area.
Thanks,
|
CRA
|
|
What is the size of your institution? If you are a Small or Intermediate Bank you may adjust the boundaries to include only the portion of county you can reasonably be expected to serve; they must be contiguous whole census tracts. (See section __16.(b)(3) in the Common Rule.)
We are an IB with two Branches. Under the existing rule, we defined our Assessment Area as our city’s geographic footprint and surrounding farmland. Our MSA covers two counties, and our city is in a corner of each county. Under the Final Rule our FBA would need to be both counties, which is too big to cover for our small footprint. Our previous AA consisted of contiguous census tracts, so I am adjusting the new FBA boundaries to the same census tracts per this provision. In other words, no change.
I’ve talked with a couple of other small banks that have done the same. The proof will be in the pudding!
|
CRA
|
|
I have a similar question on this subject:
We have an AA that is 2 contiguous counties. We have 1 branch. Each county is in a separate MSA. Under the new rule, we cannot have an FBAA that includes more than 1 MSA, so I am left with the following decision: 1) remove the county that does not contain our branch. It will likely become a component geographic area in our ORLA, or 2) separate this area into 2 FBAAs. Each FBAA would be 1 county.
Honestly both options are bad. We are dealing with large counties where we have will struggle to hit these new benchmarks (I think my option 1 would be best).
Am I on the right track with my line of thinking? These are my only options?
|
Marketing
|
|
I am amazed that banks spend untold hours trying to teach customers not to click on links in e-mails that say they are from the bank so as not to get fished or hacked. Then banks turn around and send e-mails to customer that say, please take this survey and start by clicking this link.
I am also unsure how the ECOA would apply to this survey and why it would be a UDAAP.
|
Marketing
|
|
We are wanting to email our online customers with a survey and entice their opinions with a drawing (1 winner will receive $500)? The catch is the survey and drawing are open to residents who are between the ages of 24 and 40 years with children under the age of 18.
My concern is this could be a UDAAP and ECOA issue as some parents may be older or younger.
Thoughts?
|
eBanking / Technology
|
|
We too now have a customer who had the incorrect amount debited from their account for a service they had received. Are we to provisionally credit the full charged amount or just the difference between the incorrect amount and the true transaction amount?
|
Flood Compliance
|
|
Thank you for the reference.
|
Chat! - BOL Watercooler
|
|
"Go ahead, make my day" is a catchphrase from the 1983 film Sudden Impact, - Compliance - "Go ahead, make my compliance exam a PASS".
|
Flood Compliance
|
|
If it is legally structured as a condominium and there is no RCBAP, then the single unit would be eligible for a dwelling policy. I am not sure it is insured correctly. See page 3.70 in the Flood Insurance Manual.
https://www.fema.gov/sites/default/files/documents/fema_nfip-flood-insurance-full-manual_102022.pdf
|
Chat! - BOL Watercooler
|
|
I Get Off On It--Tony Joe White
|
Chat! - BOL Watercooler
|
|
Peace Train--Cat Stevens
|
HMDA
|
|
Agree on all counts.
|
Chat! - BOL Watercooler
|
|
"I find your lack of compliance disturbing" - Darth Vader, A New Hope
|
Chat! - BOL Watercooler
|
|
Crazy Train - Ozzy Osbourne
|
Flood Compliance
|
|
The appraisal says it is "legally structured as a condominium" but there is no homeowners association, so no RCBAP. The 2 units are semi-connected to each other - according to the appraiser - and "elements have similarities to a single family residence". There are 2 APN's which is how we are taking an interest in only one unit. The homeowners is presenting us with a dwelling policy covering both units as if it was one building.
|
Flood Compliance
|
|
If this is a duplex, how can you only take an interest in one side. Do they have separate title and property descriptions? Is this a multi-family townhouse or condo association?
|
The BOL Couch
|
|
So awesome! MUCH congrats to you! Thank you so much for the decades of help, advice, and commentary you've provided our industry!
|
HMDA
|
|
Need your expert opinion, please. We have a loan for the purchase of a mobile home park, which will not be pledged as collateral. The loan will be secured by the borrower's primary dwelling. I am of the opinion that the loan reports as purchase and we report the property address of the dwelling, which is pledged as collateral, 1 unit, and as site built.
|
Flood Compliance
|
|
We have a similar situation - one building with 2 dwelling units. The owner lives in one and rents out the other. She has one flood policy covering the entire building (in the amount of $250,000) and our security interest is only on unit A (which is where the owner lives). Does the policy need to break out how much flood coverage is on each unit in this case? And then we determine adequate coverage based on loan amount, RCV or maximum under the NFIP?
|
CRA
|
|
Thank you
|
CRA
|
|
.43 Content and availability of public file.
(a) Information available to the public.
A bank must maintain a public file, in either paper or digital format, that includes the following information:
(7) Any other information the bank chooses.
|
CRA
|
|
We are a large bank now, but in 2026 we would be intermediate-small. For the public file update, we are not required to include the loan-to-deposit ratio as a large bank; can we still include it since eventually we will have to add it when we become small-intermediate?
Thank You,
|
HMDA
|
|
5. Purpose—business or commercial purpose loans. If a covered loan primarily is for a business or commercial purpose as described in § 1003.3(c)(10) and comment 3(c)(10)-2 and is a home purchase loan, home improvement loan, or a refinancing, § 1003.4(a)(3) requires the financial institution to report the applicable loan purpose. If a loan primarily is for a business or commercial purpose but is not a home purchase loan, home improvement loan, or a refinancing, the loan is an excluded transaction under § 1003.3(c)(10).
|
HMDA
|
|
So this would be reported as "refinance" since it's a multi family and free and clear? To be a refinance, it would have to satisfy and replace an existing dwelling-secured obligation. It sounds like a home improvement purpose from your initial post...
|
HMDA
|
|
So this would be reported as "refinance" since it's a multi family and free and clear?
|