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CRA
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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,
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CRA
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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!
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Marketing
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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.
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eBanking / Technology
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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?
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Flood Compliance
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Thank you for the reference.
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Chat! - BOL Watercooler
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"Go ahead, make my day" is a catchphrase from the 1983 film Sudden Impact, - Compliance - "Go ahead, make my compliance exam a PASS".
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Chat! - BOL Watercooler
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I Get Off On It--Tony Joe White
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Chat! - BOL Watercooler
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Peace Train--Cat Stevens
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HMDA
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Agree on all counts.
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The BOL Couch
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So awesome! MUCH congrats to you! Thank you so much for the decades of help, advice, and commentary you've provided our industry!
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HMDA
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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).
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HMDA
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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...
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Flood Compliance
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I agree with Scott. The borrower is in default on his original loan, and you want to loan him more money? However, the answer to your question is yes. I am assuming you have force placed the maximum amount of flood coverage on the first loan.
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FCRA
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You are correct. You are actually under no obligation to the borrower to report any loan to a credit bureau. Regulatory wise, you have to make sure that you fairly report, if you are reporting. Unfair/inconsistent reporting among a class of loans could be considered a fair lending issue on the servicing side of the loan or violate the data integrity regulations (Appendix E to Part 1022).
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FCRA
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Well, if there is an active-duty alert or extended fraud alert, that automatically opts them out of unsolicited offers, unless they specifically ask to not opt-out from pre-screened offers.
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HMDA
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Are we correct to report this as a home improvement since the funds are being used to improve the residential portion of the property?
IMO, yes.
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Need to Remain Anonymous
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For daily simple interest loans, if your note is not crystal clear about the standard handling of payments scheduled for non-business days, then there is, at a minimum, an opportunity to reduce cost--the cost of handling borrower inquiries and complaints. Take your example and make Monday a holiday. If my bank sends me (or allows me to see) a record showing my payment was "posted" on Friday, but the interest clock continued running until Tuesday, I'm irritated. I may complain to a bank employee, maybe a consumer advocacy organization (private or state/local government), and maybe to your regulator.
Although a practice may be legal and will withstand a UDAAP challenge, why look for ways to waste time and money? Reword these notes to include a discussion of the effects of payments (customer-initiated, as well as automatic) scheduled on non-business days.
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HMDA
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Thank you Dan I appreciate it. I will forward on to my manager.
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BSA/AML/CIP/OFAC Forum
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It seems the FDIC would agree with you, and so do I.
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CRA
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It starts on page 1,371 of the monstrous document.
At least 30 days before the beginning of each calendar quarter, the Federal Reserve System publishes a list of the banks that are scheduled for CRA examination by the Reserve Bank for the next two quarters. This list is available from (title of responsible official), Federal Reserve Bank of ____ (address), or through the Board’s website at https://www.federalreserve.gov. You may send written comments about our performance in helping to meet community credit needs to (name and address of official at bank) and (title of responsible official), Federal Reserve Bank of ____ (address), or through the Board’s website at https://www.federalreserve.gov. Your letter, together with any response by us, will be considered by the Federal Reserve System in evaluating our CRA performance and may be made public.
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CRA
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In prior years, the public file contained not only our assessment area maps-full counties-but also adjoining county maps were included. Is there a requirement for the adjoining county maps to be in the public file?
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Deposits and Payments
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Page 13 of of the Final Rule
" The amendments made by this final rule will take effect on April 1, 2024. However, full compliance with the amendments made by this final rule is extended to January 1, 2025."
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eBanking / Technology
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Do you provide e-statements? Will they be able to access their final statement if they are signed up for e-statements?
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Need to Remain Anonymous
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IMHO - the podcast itself is an oral advertisement. I don't think that just having the advertising statement on the launch pad meets the spirit of the regulation. Plus, I am not sure that you can prevent direct access to the podcast if someone has the web address that would allow them to bypass the launch pad. But that goes beyond my technology knowledge. Even generically, if NDIPs are mentioned or alluded too, that further complicates matters.
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Lending Compliance
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Thank you brother!
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