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Need to Remain Anonymous
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I just learned that we are considering charging an advance fee on our ODP accounts and increasing the interest rate (which has been very low for many years). It is my understanding that the rules regarding CITs will change with the Phase II Propos
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Texas
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Does anyone accept consular/matricula cards from any other country besides Mexico?
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General Discussion
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I wonder if there is anyone out there has the experience of upgrading a foreign agency to a foreign branch? Is there a requirement to put in (i) additonal capital funds and (ii) increase reserve? Thank you in advance
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Lending Compliance
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We closed a construction loan. There was a problem with the property so the borrower chose a new location and we closed a second construction loan. No additional fees were collected for origination or inspection on the second loan. Should they st
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Need to Remain Anonymous
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Our credit report vendor is going to be charging us one flat fee per loan that will cover all of these services: Credit Report Mailing of Credit Score Disclosure AVM (appraisal comps) Xtra Fraud Reports on Credit Report How do I disclose this on
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Operations Compliance
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I have looked at CC and I searched the forums but just can't find an answer, HELP! If a bank needs to use the Emergency Option, how many days may we hold the local and non-local checks? Or, is there not an answer because we simply put down the actu
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CIP and BSA/PATRIOT Act Issues
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Has anybody installed this software to assist with BSA, ITPP, and Fraud? We are having a webinar with them next week to see how they could possibly help us. I would appreciate any feedback, good or bad.
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Operations Compliance
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This notice creates a pilot program allowing filers of information returns to truncate an individual payee’s nine-digit identifying number on paper payee statements for calendar years 2009 and 2010... Interesting, albeit belated, nod toward pre
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Article 9
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We are refinancing a loan from another bank. We have asked them to assign their UCC financing statement to us. We have our own note and security agreement. Are there any hoops I should be looking for in order to perfect and retain the other bank
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Pennsylvania
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Our Bank is a National Bank which sometimes uses Pa State licensed Mortgage Brokers. Is the Broker required to give the borrower a Consumer Mortgage Disclosure Form and if the Broker does not, are we as the Lender required to make sure the form is g
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eBanking / Technology
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Has anyone used Suntell SquareOne Credit Suite. We are looking at purchasing this software for Document Imaging (not check imaging). Just wondering if anyone has had any experience with this software. What are others using for Document Imaging?
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Lending Compliance
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If the bank gets informaiton from the customer on June 1 to begin an applicaiton, but does not include a property address or information to do comprehensive underwriting and then gets that information on June 20 do you use the 20th for HMDA applicati
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Lending Compliance
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We are currently working on developing our RESPA required service provider list. We only allow the applicant to shop for settlement services. On our list will be our affiliate, which we know will require an ABA disclosure. I have heard that under
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Operations Compliance
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Would anyone be willing to share the form letters they use to respond to customer EFT error claims?
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Deposits and Payments
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What would be the proper endorsements on a check written by a customer to an Insurance Agent, but the check is made payable to the Insurance Company. e.g. Customer makes check payable to USF&G, but give it to the local agent office of Smith &
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Lending Compliance
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Am i correct in thinking that the bank can charge the borrower for any settlement service as long as they don't pay more than the actual cost of settlement?
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Operations Compliance
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Can anyone tell me about the requirement for providing a phone number for a credit counseling service in regards to the CARD Act of 2009. I have seen that we need to provide one phone number and I have seen where it is required that we provide three
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HMDA
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Does anyone know if the 5 year seconds for the Federal Loan Bank program are HMDA reportable? It is money that does not have to be repaid unless the borrower does not reside in the house for 5 years. The money comes from the FHLB First time homebuy
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Massachusetts
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Any thoughts on where to disclose the reciept of the MLC? I am guessing box 4 on GFE under title services since it doesn't fall into any of the other categories. Recording the MLC would go in appropriate recording section. Thanks!
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Operations Compliance
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We have noticed IRDs being returned to us up to two to three weeks late by the Fed since it began sending all items through the Cleveland office. It does appear the other bank is returning timely, but we don't receive the image for another two weeks
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Audit
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Has anyone written up any audit procedures for this they would care to share?
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CRA
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We recently had a discrimination complaint that we resolved by conciliation. What do we need to disclose in our Public File on this?
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General Discussion
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We are trying to find some sort of model or spreadsheet or just ideas for what to use for performance measures for our operations staff. We have recently moved to the "sales" and "operations" areas instead of everyone does everyt
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Lending Compliance
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Can the appraisal fee, credit report, tax service fee, and/or flood certificate fee be rolled up into your origination fee charges and not itemized out on the GFE and or HUD-1 if these services are performed by a third party? Does this allow you to
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Lending Compliance
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We have a loan that has been renewed, and the escrow for property taxes and insurance was miscalculated. After re-calculating the escrow, the loan amount increases. Will right of rescission apply when we re-disclose?
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