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Real Estate Lending Record Keeping Record Retention Red Flags Referral Refinancing Reg AA Reg B Reg BB Reg C Reg CC Reg D Reg DD Reg E Reg F Reg FF Reg GG Reg H Reg J Reg M Reg O Reg P Reg Q Reg R Reg U Reg V Reg W (HUD) Reg X Reg Y Reg Z Regs Regulators Remote Deposit Capture Renewal Reporting Repossession Representative Payee Research RESPA Return Items/Checks RFPA Right of Offset Right of Rescission Risk Assessment/Risk Management Robbery Routing Numbers denotes Guru Question & Answer. Real Estate Lending Calculating the LTV Guarantor on a Consumer Real Estate Loan ROR on Construction Loan Modification MDIA Disclsosures Supervisory LTV Limits Reporting TIL Issued for Residential Investment Property The SAFE Act New Appraisal Required? Reg B - Business Loan Credit Decision Timing About the Home Equity Conversion Mortgage HOEPA Exemption Sales of Residential vs Development Properties Commercial Real Estate Delinquencies Closing Fee a Pre-paid Finance Charge? Secondary Market Mortgage Loan Disclosures Reclaiming Money on a 2nd Second Mortgage Defined Pre-Paid Finance and Financed Costs Mortgage Promotion Loan Withdrawal OCC Handbook - Interpretation of RESPA Exemptions Multi-Family Property Reporting Spousal Right of Rescission Business Purpose Loan - RESPA Applicable? GMI Collection � Purchase of Primary Residence Mortgage Relief Scams Real Estate Lending & Trusts Appraisal Rules HMDA � Which Date Do We Use? Home Mortgage Refinance - Flood Search Required? Tax & Insurance Premium Escrow Accounts Delinquent Mortgage - Escrow Analysis Guidelines About the Making Home Affordable Program HOEPA & Bridge Loans Signer Pledging Interest - Appraisal Notice Given? HUD Fee Disclosures Resubmit Disclosures in Surviving Spouse's Name? Disclosure Required on LTV Ratios Change? RESPA -Residential Lot Loan Secured by Residence Appraisal Review Fee Independent Appraisal � Notice Still Applicable? LTV Reporting Rule Changing LTV Ratios Underwriting Fee Charge Fair Lending - Income Verification Higher Priced Mortgage Loan Rules HUD 1-A Form Line 1604 Provide Copy of Appraisal on Commercial RE Loans? SCRA Notice in Past Due Mortgage Notices? RESPA � Title Company Broker Fee Disclosing PMI Provider Web Linking from a Realtor's Site to our Mortgage Site Purchased Note - Treat as Refinance? About the Housing and Economic Recovery Act HOEPA - Combined Transaction Loan App Withdrawn/Denied - Collecting an Appraisal Fee Phone Apps & Collecting Government Monitoring Data ROR on Refinance of Non-Owner Occupied Home Offering A and H Insurance on a Real Estate Loan Second Homes Subject to ROR? Supervisory LTV Limits Mortgage Modification - No Need for Redisclosures? RESPA Bridge Loan Exemption Extending a Revolving Line of Credit, Give ROR? Dating the Application ROR on Second? Collect Applicant Info on Non-Reportable RE Loans? Refinance New Note with No New Money - ROR? PMI Disclosures on Non-Owner Occupied Property Flood Certification Flood Penalties Purchasing a Home on Contract - ROR Required? Mitigating Mortgage Fraud: Application and Other Misrepresentations Use of Evaluations in Lieu of Appraisal Compliance with the Appraisal Regulations Bridge Loans & HMDA RESPA & Vacation Homes MARI Releases the Tenth Periodic Mortgage Fraud Case Report Flyers Advertising Mtg Rates � Do�s & Don�ts Certified Real Estate Appraisal Required? Determining the Correct Occupancy Code Determining Income HMDA Reporting on a Commercial Line of Credit Curbing Mortgage Fraud Business Purpose HELOCs? Referral Fee to Customer Hunting Camp - HMDA Reportable? C and I Loan - Signed W-9? Sending 1098s Applications Online Flood Insurance Coverage Conundrum Signing the GFE on a Refinance Using Federal Tax IDs in Fighting Mortgage Fraud Provide Another GFE? Mandatory Purchase of Flood Insurance SMB Loan Portfolios Lowering Interest Rates on Existing Mortgages Mobile Home Equity Loan? CREs and TDRs Loan Modification Procedures Loan Consolidation Mortgage Change in Terms - New Disclosures Needed? Investment Property - Residential HELOC Financing TILA Signed by Non-borrowing Spouse Earning Credit Second Mortgage HMDA Reportable? In Search of a Real Estate Loan Spreadsheet Review Appraisal - FIRREA Violation? Drive-by Appraisal Residential Lot Purchase - Maximum Regulatory LTV Rescindable Loan & Amount Rescindable? P and I Payments - HMDA Reporting Real Estate Settlement Booklet Reg B - Which Form Do We Use? FDIC Flood Audit - Pulling the Flood Cert Bridge Loan, Purchase Money & ROR Rescission & Loan Doc Date Dilemma Calculating Amount of Required Hazard Insurance Timeshare as Collateral In-house Appraisal Based on a Tax Assessment Flood Insurance Coverage - No Appraisal Loan Commitment Required on a Mortgage Transaction Biweekly Mortgage Payment Agreement Flood Insurance - Extreme Home Break-over Documents Signed by Non-borrowing Owner Construction Loan Converted to Perm Financing Non-owner Occupied HELOC - ROR Period RESPA Bridge Loan? SCRA Notice - Mortgage Only or All Borrowers? HUD Form - Bank's Responsibility Determining Builder's Risk Coverage Flood- Force Place Per Customer's Request? Application Denied - RESPA Disclosures Given? Making Quality Lending Decisions HMDA Reporting- Dwelling Being Converted to Office One Loan for Two Properties - HMDA Reporting Oops! I Don't Wish to Cancel HMDA Reporting on an In-house Renewal Equity Line of Credit - Exempt from ROR? Loan Renewal - Flood Certification Notice HMDA Reporting on Bahamian Condo Rental Property Purchase - Final TIL HMDA - Rate Spread Reporting Mortgage Fraud Lender's Name Typed Not Signed on Mortgage RESPA and/or HMDA Applicable? GMI - Finance Purchase Price of Primary Residence Construction Loan Increase - New Note Needed? 1099 Required for Gift Check? FASB Documentation Fee Disclosure Flood Insurance - 45 Days Notice to Borrower Rental Property Covered Under TIL? RESPA - Personal Residence Construction Loan Automating Your Fight Against Mortgage Fraud Mobile Home, No Land - RESPA? Does This Borrower Have a Right to Rescind? Can We Recycle this Appraisal? Raising LTV Percentage Real Estate Lending & Skip-a-Payment Programs SFR Loan Subject to Rescission HMDA Reporting - Home Loan Down Payment HELOC Rescission New Application for Renewal or Modification? Rescission for Old Home Securing the New Home Loan RESPA Escrow Rules Real Estate Loans and Bank Capital Real Estate Lending Standards - Part 365 Commercial Level Flood Insurance Amounts Property Value Determined by Tax Value Applications - 3 Day Disclosure Period Is This Loan Subject to the Regs? GFE Disclosure Limits Interest Reporting on Secondary Residence RE Loan with Two Single People Commercial Mortgage Rewrite Flood Determination Needed? State Certified Appraisal Required? Securing a New Note with a Modified Mortgage New Home Purchase - Old Residence as Collateral Brokered Real Estate Loans - Origination Fee Issue Real Estate Loan Record Retention Lending to a Religious Organization 50 Mile Rule Early Disclosures and HMDA - Refinance Are We Required to Send Monthly Statements? What are the Five Most Frequently Seen Examples of Mortgage Fraud? Modified Construction Loan FIRREA Business Loan Exemption Real Estate & 1098 Forms Please Define DSCR Requirement Spec Construction Loan officer/Realtor - Disclosure of Dual Roles Documentation for Secondary Residence Improvement Loans Length of Time for Holding OREO Property Reporting Interest on Commercial Real Estate Loans Puzzled by the OCC's Handy Chart Commercial Real Estate Loans Reg B Reportable? On Deeds, The Name Remains the Same? Financing Purchase of Real Estate Contract Is New Application Required for RE Modification? Mortgages (PDF) Are Variable Rate Disclosures Applicable? Appraisals (PDF) Curing Time for APR Disclosure Error on RE Loan All on Board the Referral Train Document Prep Fee in APR? Can We Exempt this Loan from Regulation Z? When Does A Loan Get Considered Delinquent? Realtor Referrals Real estate agent "to do" list? - Notice of Right to Receive an Appraisal Real Estate Application Requirements Commercial Lender, Consumer Purpose Loan Real Estate Lending Cheat Sheets Does Flood Apply Under Abundance of Caution? Payment Deferrals on a Mortgage Loan Lending More for Debt Servicing If a Condo Association Decides Not to Rebuild .... Seller's Disclosures of OREO Requirements on Short-Term Construction Loans Rescission on a Business Loan with a Home Pre-Paid Finance Charge Flood Determination, New Loan - Existing Mortgage Carrying Escrows Forward Is a GFE Required if We Close Before 3 Day Necessity of new appraisal Is Loan Purpose Irrelevant for 1098 Purposes? OCC addresses real estate lending calculations, limits RESPA, Reg Z, and Commercial Real Estate Loans Real Estate Employee Referral Incentive Programs Real Estate Loan Modification & RESPA Record Keeping Privacy Notice Recordkeeping of CIP Information Loan Purpose Statement Non-deposit Instrument Log Negotiable Instrument Log Entry BSA � Is Savings Bond a Monetary Instrument? Avoiding Risk with Paperless Transactions CTR Filed on Exempt Customer Monetary Instrument Log Record Retention The Importance of Record Retention BSA Recordkeeping - Same Day Transactions Only? Monetary Instrument Sales Form and Log Statement of Purpose Annual Financial Disclosure Statements Auto Dealership/Recordkeeping of Credit Reports Reg O - Recordkeeping of Insider's Family Members Monetary Instrument Purchased by Employee CIP Record Retention on Sold Mortgage Loans Record Keeping of OFAC Screen Prints Best Practices for Website Record Retention BSA Record Keeping Requirements on Loans TIL Retention To Image or Not to Image, That is the Question Record Keeping on Paid Loans Authority for Imaging Retaining Construction Advance Documentation $3,000 Cash Sales Record Requirement Clarified: Cash Deposit / Debit Now Must Be Recorded Section 326 Takes Over: "The Devil Is In The Details" One 326 Problem Account Number Truncation Are These "Errors" Under Reg. E Retrieving Data from Old Media CIP Record Retention Destroying 314(a) Search Requests Marketing Retention Altering Collection Notes Destroying Signature Cards Industry Standard - Microfilming Daily Work Required BSA Records Verification Of Source Documents For Master File Changes Inadequate Recordkeeping by Debtor Leads to Denial of Discharge Record Retention Requirements Record Retention Requirements For Student Loans Update on Student Loan Record Retention Important! Please Read! Questions & Answers Followup Question & Answer Search Warrants & Subpoenas Check Imaging For Lockbox Becomes Standard Imaging Of Checks Catching On What if They Want a Copy Of Our Picture? "Are Your Safe Deposit Procedures Ready For A Subpoena?" Quick I Need A Copy Of A Check!" We Are? Question & Answer Question & Answer EDITORIAL - We Have To Do WHAT ?! Question & Answer Question & Answer Question & Answer Question & Answer Record Retention If You Need To Produce Records In Court� Question & Answer Question & Answer Good News�Bad News No Summons Or Subpoena?No Records! Record Retention Long-Term Storage, What to Keep, What to Toss Website Changes & Website Record Retention Retention of Website Pages Retention of Electronic Disclosures Credit Verification Retention Denied Loan Retention Schedule Monetary Instrument Log Record Retention ATM/Debit Card Applications Retention Adverse Action- File a Copy of the FCAI Disclosure Advertising Material Record Retention Debit Card Retention Website Screen Record Retention The Importance of Record Retention RESPA Record Retention Participation Loan Record Retention Paper Checks from a Remote Deposit Electronic Document Retention by a Consumer BSA Retention Policy & Loan Documents Bank Statement Returned Mail Compliance Commercial Loan Record Retention ACH/Ebanking Reports & Records Retention Adverse Action Letter Retention E-Statement Retention - Fed Rules Notice of Action Taken - Retention Period Over the Counter Check & Deposit Record Retention Business Email Retention Remote Deposit Banking Imaged Check Retention Returned Statement Record Retention Forgeries and Check 21 CIP Form Record Retention Security Video/Digital Retention Credit Denial Record Retention Interactive Voice Response System Retention Real Estate Loan Record Retention CIP & OFAC Record Retention Guidelines Retention of Rate Information or Sheets Retention of Credit Card Cash Advance Slips Destroy the Originals but Keep the Scanned Copies E-mail Record Retention Scan the Signature Card, Keep the Original? CIP - Retaining Photocopy of Customer Credit Card Retention for Processing Credit Card Applications CD Record Retention Best Practices for VCR Tapes Technology Related Record Retention Reg DD Products - Minimum Dollar Amount Stated CIP Record Retention on Sold Mortgage Loans Retention of Cashier's Check Log Best Practices for Website Record Retention Record Retention for Imaged Loan Documents TIL Retention OFAC - Record Retention Maintaining Checking & Saving Account Records Record Keeping on Paid Loans Retention of Denial Documentation Returning paid documents Record Keeping on Paid Loans How can I retain customers that are refinancing their mortgage? Retention of Electronic Applications Record Retention for Internet Banking & Bill Payment Retention of Declined Debit Card Applications Record Retention of Audits Retaining Returned "Bad Address" Privacy Notices Retention of Trust Account Files After Closing HR Record Retention 314(a) Record Retention Retention of rate information or sheets Authority for Imaging Records Retention more than 5 years? Record Retention for Internet Banking Retaining eMail Retention of OFAC and 314a Records Guru Compilation: Record Retention (PDF) Record Retention: Converting from Obsolete Media Record Retention: Maintaining Multiple Storage Systems Account Number Truncation SCRA records retention Email Retention Reg. B -- Withdrawn Application CIP record retention Retaining I.D. in CIP loans Record Retention for NSF Record Retention for Denied Loans Surveillance Film CIP Record Retention Retention Period on Home Equity Loan Files Retention Schedule for Changes of Address Retaining Records Regarding Forgeries Retention Period for Paid Off Loans Email Retention Guidelines CIP Record Retention Requirements Keeping Copies of Advertising How long must HUD escrow accounts be kept and is computerized storage okay? Database Of Closed Accounts How Long to Keep? Retention Requirements For Email and Network Files Record Retention on Prescreening CIP: Record Retention For Business Account Information Record Retention & E-Statements Record Retention Schedule Needed Is It Necessary To Save Teller Trash? Retention of Loan Customer Driver's License Info Surveillance Tape Retention Schedule Record Retention Requirement For Imaged Checks Record Retention Policy Guidelines Retention Requirements: POAs & Death Certificates Retention Period For Lending Documents Online Access Agreements & Hard Copy Retention Requirements Record Retention Requirements For Money Market/Savings Letters ACH Origination File Retention Requirements Signature Card Retention Requirements Record Retention Requirements For Marketing Materials Privacy: Record Retention Requirements For Opt-Out Notices Y2K Record Retention Requirements Record Retention: How long do we keep dead files? Mail Envelope Retention Record Retention Requirement For Checks Red Flags Red Flags Special Edition Revisions to the Red Flags Program Without Recourse Endorsement - Bank's Recourse Major Concerns with the Identity Theft Red Flags Rule Mortgage Relief Scams Red Flags Rule Compliance Red Flags in Your Vendor Population Your Vendors & Red Flags: What you don't know can hurt you Red Flags Rule - May 1st deadline Red Flags Rule Requirements for Small-business Portfolios Red Flags Rule � Small Business Loan Requirement? Scoring Compliance to Identity Theft Red Flags Red Flags � Monitoring Address Changes Marriage, Divorce, Name Changes & Red Flag Rules Red Flags - Highest Risk Customers Red Flag Checklist - Maintaining an Account Risk and Trade Finance Red Flags Rule compliance - Do regulators expect to see a log of detected activity and resulting mitigation? Referral Volumes as an Operations Concern The Identity Theft Prevention Program's Impact on Customers Dealing with Account Authentication Implementing the Red Flags Change of Address Verification Requirement Requirements for Guarding Against Phishing Scams The Great Debate: Credit or Public Records Data FACT Act Identity Theft Prevention Program Mandates Referral Volumes as a Significant Operations Concern ID Theft Red Flags Examination Procedures Complying with the New Red Flag Rules: A Recipe for Success On What do Red Flag Examiners Focus? Red Flag Rule Compliance: 5 Things You Need to Know For What do Red Flag Examiners Look? Financial Crisis: Identity Theft Puts Banks at Greater Risk Implementing the Change of Address Verification under the Red Flag Rule Calculating the Expense of Red Flag Regulations Implementation Guarding Against Phishing Scams Silver Lining in Red Flag Rule: Bankers Can Generate Revenue and Increase Customer Satisfaction Policies and Procedures Manual for Red Flag Compliance Identifying and tracking account risk is part of the Red Flag program, do you know what these requirements include? Red Flags and BSA/AML programs involve twelve critical functions, do you know what they are? Red Flag Program � do I have to use all 26 Red Flags? How should my bank respond to the Red Flags Rule requirements effective Nov. 1st? Implementing Red Flag Compliance Measures before the November Deadline Financial Institutions Up in Arms over New Red Flag Regulations Policies and Procedures Manual for Red Flag Compliance Red Flag Program � Service Provider Arrangements Fighting Fraud Takes a Mix of Tools Address Changes and Card Replacement Staff Training for Red Flag Regulations? For Financial Institutions, Identity Theft Protection is a No-Brainer Red Flag Program � oversight from the Board Red Flag � Separate Program Required? Identity Theft Red Flags Is Your Financial Institution Red Flag Ready? New Ways To Fight Identity Theft Getting Compliant: The 7 Step Red Flag Checklist Phishing for a Banking Solution Risk Assessment for Red Flags involves both creativity and math! Red Flags overlaps BSA/AML, do you know where to look? Do We Really Need an Anti-Phishing Program? Program Requirements for Red Flag Compliance An Example of a Red Flag Use New Red Flag Checklist on All Customers? Policies and Procedures Manual for Red Flag Compliance Key Areas to be Addressed for Red Flag Rulings Compliance with the Red Flag Ruling Crackdown On Compliance Referral Refer a Friend Referral fee for business accounts FHA Loans - Referral Fees NDIP Referral Fees Third Party Originator Referral Fee Pay Bank Employees for Mortgage Loan Referrals Gifts to Top Loan Customers Paying Tellers a Referral Fee � RESPA Violation? Web Linking from a Realtor's Site to our Mortgage Site Deposit Incentive Referral Volumes as an Operations Concern Commercial Loan Referral - Paying a Finder's Fee RESPA - Prospect List Provided by Title Company Bank Flyers at Dealership & RESPA Referral Fees Referral Fee to Customer Privacy - Is Vendor an Affiliate? IRS Reporting - Customer Referral Cash Bonuses Weblinking & RESPA's Section 8 New Account Sale - Referral Fee HELOC Visa Referral and Rewards Program Splitting Advertising Costs - RESPA Violations? Lurking RESPA Violations? Realtors Appreciation Evening Reverse Mortgage Referral Fee Splitting Advertising Costs - RESPA Violations? Hors d'oeuvres and Drinks Revamping Our Refer a Friend Promotion Paying a Referral Fee for Done Deals? Refer a Friend Giving Gifts to Auto Dealers for Loan Referrals A Bottle of Wine, Prison Time & a 10 Grand Fine Outside Vendor Paying for Customer Referrals RESPA Referral or Just Doing Lunch? Referral Fee from a Mortgage Broker Lending referrals Realtor Referrals Mortgage Broker Looking for Answers All on Board the Referral Train Is the Competition Breaking the Law? Referral Fee for Commercial Loans Lending referrals Affiliated Business Disclosure for HELOC Referral Paying RESPA Referral Fees Loans and Kickbacks Realtor Referrals Referral Fee to a Broker for Auto Loans Free Phone Card - Getting a Referral In Return Is This a Permissible "Quid Pro Quo"? Promotion Idea for Realtors Dollar Threshold for "Thank You" Gift to Borrowers Offering Consumers a Fee for Customer Referral Vacation Package in Exchange for Loan Referrals Who is responsible for determining if services were provided? OFAC Referrals? Paying Mortgage Referral Fees Customer Referral Rewards Program Encouraging Realtor Referrals RESPA Referral Fees Paying for Loan Referrals RESPA arrangement definition Referral Fees for Commercial Referrals RESPA Section. 8 Incentives Gift Certificates for Mortgage Referrals Brokers, referrals, and commercial borrowers Broker referral fees Referral Programs & Lotteries Mortgage Referral Fees Referral Fees For Commercial Loans Can we pay tellers for referrals to our own mortgage company? Refinancing When is a Bridge Loan No Longer a Bridge Loan? New Guidelines - Charging a Refinance Fee New Reg Z Rules - Matured Loan Renewal Versus Refinance Loan & Filing Fees � Trigger ROR? Refinance or Renewal? HMDA � Loan Renewal/Increase on Rental Property HMDA Reporting - Permanent Financing HMDA - Data Reporting Owner Occupancy HMDA Re-file Home Mortgage Refinance - Flood Search Required? Refinancing for a Better Rate � ROR Applicable? HMDA Reporting � Mixed Used Property Loan Three Year Balloon Mortgage GMI on Refinance Q & A - Clarification Needed Refinance Denied � Send Adverse Action Form? Duplex Refinance HMDA - Double Reporting? HMDA � Report as a Purchase or Refinance? RESPA - Rental House Refinance Paying Tellers a Referral Fee � RESPA Violation? Purchased Note - Treat as Refinance? Is the Assumption a Refi or Purchase Purpose Loan? Is This HELOC Renewal Considered a Refinance? ROR on Refinance of Non-Owner Occupied Home Change in Terms, No New Money, ROR Needed? Reporting Non-Mortgage Loans under HMDA Mortgage Modification - No Need for Redisclosures? Bridge Loan Extension- Early Disclosures Required? CIP - Bank Director Refinancing Second Home Special Information Booklet and Refinancing Extending a Balloon Loan - Disclosures Required? Refinance New Note with No New Money - ROR? GMI on a HELOC - Home Purchase or Refinance HMDA - Extending a Current Obligation GMI on Refinance Refinance of Primary Residence - Collecting GMI HMDA Reporting - Commercial Loan Refinance ROR Triggered by "Left-Over" Cash? HMDA Reporting - Commercial Loan Refinancing Signing the GFE on a Refinance Provide Rescission Period to the Borrower? HMDA - Recouping Home Improvement Costs Loan Modification Procedures HMDA -Short Term Loan Refinanced for a Longer Term Deceased Applicant - HMDA Reporting? Refinance or Purchase for Disclosure Purposes? Temporary or Permanent Financing? Documents Signed by Non-borrowing Owner ROR on Refinanced Loan HMDA Reporting on an In-house Renewal HMDA Reporting on Bahamian Condo Mixed-use Property Rules - HMDA Reporting Business Loan Renewal - HMDA Reporting HMDA Reporting - Refinance of Rental Properties Outstanding Interest Farm Credit Loan Refinance - HMDA Reporting SFR Loan Subject to Rescission HMDA - Refinance of a Short Term Loan HMDA Reporting of a Home Improvement or Refinance Loans Subject to HMDA Is this Renewal HMDA Reportable? HMDA Filing Help Assisted Living Facility - HMDA & CRA Reportable? ROR on Refinance Reamortizing Loan Payments � New Disclosures? HMDA - Refinance of Time Share HMDA Reporting on a Cash Out Refinance Loan Cash Out Refinance ROR - Home Refinance with New Money ROR on Two Loans Refinanced into One Loan Early Disclosures and HMDA - Refinance Do We Need Early Disclosures? Do I Send a GFI, and is this Temporary Financing? HELOC - Notice of Right to Cancel Not So Fair Lending? Refinance 2nd Home Is a Loan Renewal HMDA Reportable? HMDA - Definition of a Refinance HMDA - Definition of a Refinance Another Multiple Properties Question Early TIL on a Refinance Is New Application Required for RE Modification? Legality of Consumer Balloon Notes Refinancing a HELOC as an ARM Collecting the Correct Interest for Renewal A HOEPA or Not a HOEPA - How to Tell CRA or HMDA? Reg O - Mortgage Loans Sold to Investors Waiving ROR on Refinance of Principal Residence Refinance or not? Benefits of Cash-Out Refinancing HMDA Refinancing -- Defined How can I retain customers that are refinancing their mortgage? HMDA and the Mobile Home Park Early Disclosures for Bridge Loans Section 32 Loan Question Are Home Equity Loans HMDA-Reportable? Paying Mortgage Referral Fees Rescission on Renewed & Increased Amount If There is no Recorded Lien, is it a Refinance HMDA Refi vs. Modification Carrying Escrows Forward Waiving the Right of Rescission What "Note" Makes it HMDA Reportable The Masses Are Still Confused on Refinancings HMDA Refi Test Rescission on Interest and Fees Early Disclosures on Refinance by Same Lender Rescission, No New Money Improve Loan Production During Rising Rates Changing Rate on Balloon Loan Commercial Loan Now HMDA Reportable Business Purpose Loan, Residential Refinance, and HMDA Prequals Under HMDA HMDA Revision of Definitions/Rules "Buying Your Home" Brochure Disclosure Recission Rights Upon Modification Changing Credit Limit on HELOC Distinguishing Between Renewal and Refinancing Early TIL Disclosures on Refinance Time Restriction Before Refinance Can Occur Under the Revised HMDA Regs Is new information required on every application? Does refinanced loan fall under HOEPA? Refinancing: When does the interest accrual stop on the original loan? Refinancing and rescinding Dwelling Refinance, Debt Consolidation, and HMDA What is the official definition of the lending word "refinance"? Ready for Refinancings? Reg. AA Reg. AA - Unfair or Deceptive Acts or Practices Loan Guaranteed, Not Cosigned � Compliance Issues? Co-Signer Required to Sign the Notice? Reg AA - Address for Consumer Complaints Consumer Loan and Cosigner Procedures In Need of Reg AA Clarification Regs Governing Comaker/Cosigner Notification Father Guarantor of Son's Loan Wedding Ring as Loan Collateral Cosigners and Guarantors Purchase Money Loan for Wedding Ring Household Goods as Collateral -- Reg AA Question Reg. AA and Pyramiding Late Fees Late Fee Begets Late Fee Disclosure to Cosigners Co-applicant vs. Co-signer Lending Disclosures at a Glance Question & Answer Question & Answer Reg. B Reg. B - Equal Credit Opportunity Guarantor on a Consumer Real Estate Loan Changing the Credit Card Agreement Adverse Action Notice � Technical Error Are Credit Unions Subject to Reg B? Commercial Loan � Adverse Action Timing Reg B - Business Loan Credit Decision Timing Commercial Loan - Appraisal Notice Required? Credit Report & Flood Determination Fees ECOA, Reg B & Risk Mitigation Collect GMI on a HELOC? Possible Regulation B Violations? Reg B � Listing Order of Applicants The Equal Credit Opportunity Act Reg B - Completed Applications GMI Collection � Purchase of Primary Residence Business Loan Denial Notice Listing Reason for Denying Loan Applications Reg B � Joint Credit & Cosigners No Longer Offering Business Credit Cards Reg B Intent to Apply Jointly � Phone Application GMI on Refinance Q & A - Clarification Needed Not Subject to HMDA Reporting � Collect GMI? Freezing an Unsecured LOC � Notice Required? Independent Appraisal � Notice Still Applicable? Debit Card Mailing � Age 70 & Over Excluded Provide Copy of Appraisal on Commercial RE Loans? Adverse Action- File a Copy of the FCAI Disclosure Business Purpose Statement Form Borrower Discontinues Loan Application Delay Disclosures Until Completed Application? Closing an OD Protection Line - Give 30 Day Notice Reg B & Business Loans Shutting Down a Revolving LOC � Compliance Issues HELOC Suspension Letters - 202.9 Requirements Reg B, HMDA & Pre-Approval Letters Are We Required to Get Marital Status on Loan App? Reg B - Separate Apps for Joint Borrowers? Send Two Separate Adverse Action Notices? Maximum Number of Reasons for Declining a Loan RESPA Record Retention Reg B - Bulk Home Builders & Apartment Developers We Don't Do HMDA Reporting - Do We Collect Info? Spouse Not on the Loan - Collecting Spousal Info Reg B - Father & Son Joint Applicants HELOC Documents Clarification Needed for Prequalifications Taking Phone Loan Applications - Compliance Issues Separate Loan Apps for Unmarried Co-borrowers? GMI on a HELOC - Home Purchase or Refinance Collect Applicant Info on Non-Reportable RE Loans? Reg B Form Signed on Commercial Credits? Refinance of Primary Residence - Collecting GMI Joint Applicants - Separate Adverse Action Notices Denying Credit Based on Non-Citizenship HMDA & Reg B - Temporary Financing? Mortgage Pre-approval - Adverse Action Notice Appraisal Requirements in the Construction Phase Credit Denial Form Applications Online Collecting GMI on Loans Not Reported on HMDA LAR Reg B - Application Signed With a "Courtesy Title" Business Loan Disclosures Construction Loans & Reg B Monitoring Information The Auto Dealer, the Lender & the Credit Report Reg AA - Address for Consumer Complaints Is Direct Marketing to Seniors an ECOA Violation? Consumer Loan and Cosigner Procedures Commercial Loan Record Retention Freezing a LOC - Adverse Action Notice Reg B - Which Form Do We Use? CSDS Provided Prior to Closing? Adverse Action Letter Retention Adverse Action - State Loan Amount on the Notice? Definition of a Complete Application Send Loan Denials to Applicant & Guarantor? Reg B Appraisal Requirement - Construction Loans Appraisal Fee Reimbursement Reg B - Dual Signatures Reg B - Temporary Financing Excluded for GMI Reg B - Unmarried Couple Borrowing Jointly Contacting the Applicant Declined Loans - Required Disclosures? No Adverse Action - ECOA Disclosure Required? App Withdrawn - Send Notice of Action Taken? Reg B Appplication Violation? Adverse Action on Withdrawn Application? Joint Applicants - Separate Adverse Action Forms? Business Purpose Loan Disclosures Commercial Loans - Required Disclosures Appraisal Notice for a Corporation Co-borrowers Liabilities & Credit Reports Credit Report Constitutes an Application? Reg B - Business Credit Joint Applicants New Application for Renewal or Modification? Loan Denied to Illegal Alien -- Follow-up Question Notice to Home Loan Applicant Reg B Inquiries Investment Purpose Loan-Notice & Disclosure Given? Monitoring Information - Co-applicant not Present Appraisal Fee Refund & Notice Commercial Loan with Guarantors Loan Denial Based on Net Worth Is This Loan Subject to the Regs? Providing Tax Statements as Appraisals Fact Act Letter Is Closing an Account Adverse Action? Online Loan Inquiry Credit Report Run During Loan Pre-qualification Verbal Notification of Action Taken Customer Loan Cancellation - Adverse Action Reg B - Commercial Mortgage Human Model Advertising? HMDA, HELOCs and Monitoring Information Imaged Copies of ID Credit Report - Statement of Denial Credit Denial Record Retention Commercial Loans - Adverse Action Letters Reg B Loans - Retirement Contributions as Income Cash Out Refinance Credit Life Financed on Home Loan, GMI Required? Co-Signer/Guarantor Notice after Denial Real Estate Loan Record Retention Commercial Loan and Adverse Action Notice Reg B - Intent to Apply for Joint Credit HMDA - Better to Over Report than Under Report? Does Reg B Require Free Appraisals? Non-HMDA Reporting Bank Required to Collect GMI? Is Not Reissuing a Card a Denial for Reg B? Appraisal & Flood on a Residential Lot Commercial Loans & Right to Receive Copy of Appraisal Collecting GMI on Non-HMDA Reportable Loans Loan Declined Due to Customer Filing Bankruptcy Reg B & Indemnity Deeds of Trust Notice Required for Denied Checking Account? Retention for Processing Credit Card Applications Auto Dealership/Recordkeeping of Credit Reports Collecting GM Under Reg B on Temporary Loans Keeping Copies of Drivers Licenses with Loan Docs 88 Year Old Applying for a 30 Year Mortgage Reg B - Requesting Marital Status Sending Out a Commitment Letter Submission of Information Package an Application? 30 Year Mortgage to 64 Year Old Customer Denying Credit Based on Past Bankruptcy Protecting Customer's Medical Privacy Would This Be Discriminatory? Adverse Action Notice Without Reasons Avoiding GMI Collection When Inappropriate Application Date for Prequalified Applicant Applications, Credit Reports and FCRA Disclosures (PDF) No Response from Borrower to Counteroffer Notice Given Only on Denied Loans? Credit Scoring and Regulation B Calling for Back-up, Examiner is Challenging Bank Is an Adverse Letter Required? Denying business credit: written or oral notice? Making Regulatory Burden Worse Applications "Closed for Incompleteness" Debit Card Denial Wording on Adverse Action Notice Do We Now Need Business Loan Applications? When Do I Go on the Notice of Action Taken Clock? Bare-bones Application Regulation B: The Signature Conundrum Grossing Up HMDA Income Overdraft Protection Questions and Concerns Examples of When An Adverse Action Is Needed Checking Applicants and Signatures Reg B Application Requirements Joint Applications/Loans Sold on Secondary Market Timing of Adverse Action Letter on Mortgage Loan Reg B. Commercial Adverse Action Collecting GMI on HELOC Applications HMDA Reporting on an Unreturned Loan Application Notice of Right to Receive an Appraisal Age and Product Features for Senior Accounts Clearing the Credit Report Since It Finally Paid Reg. B and Small Business Lending Reg B - Financing Insurance Premiums as Loans Loan Denial Notice FCRA guidance needed on score disclosures Regulation B: The More It Changes, The More It Stays The Same News Release Compliance Issues - Loan Program Pulling Credit Report for Bounce Protection Contents of an adverse action notice Can We Give Customer Copy of Credit Report? Collecting GMI on a Construction Loan Higher Rates for Designated Groups? Adverse Actions and the FTC's Address Selecting reasons for declining loans Are Internet Applications Like Mail Applications Collecting Government Monitoring Information ECOA and Income: When and How to Verify Senior citizen promotions & ECOA violations Loan Denials for Third Party Applications Checking accounts, overdraft protection, and adverse action notice Credit Bureau Reports Without Written Permission Guru Compilation: Reg B (PDF) Business Loans and Disclosures "Joint Credit" Acknowledgments on FS Updates Credit Bureau Reporting When Is This An Application When to Disclose a Right to Appraisal Notice Copy of ID in Loan File OK? Application of Rescission to Business HELOCs Annual policy reviews Credit Scoring Systems Under Reg B Adverse Action Notices and Co-Applicants Determining Joint App Intent Over the Phone Reg. B -- Withdrawn Application Reg. B - Complete Application Joint Credit Notice on Mortgage Applications Providing a Notice of Right to Receive Appraisal Adverse Action on Debit Card Turndowns Retaining I.D. in CIP loans Notice of Credit Denial on Joint Applicants Record Retention for Denied Loans Delivery of the Adverse Action Notice ECOA Discrimination Separate Notice of Appraisal Required Info on Credit Applications Overdraft Privilege and "Adverse Action Notices" under ECOA Time to Complete an Incomplete Application Notice for Withdrawn Applications The Only Thing Compliance And Commercial Lending Have In Common Is The Letter "C" Commercial Loan Applications And Reg B Discrimination Issues for Foreign Speaker Does a Fax Equal a Phone Call? Prequals Under HMDA Evidencing Joint Application Intent on Biz Loans ECOA Notice Requirement Industry Standard for Documenting Joint Apps Wording for Consumer Loan Apps Signature on Adverse Action Notice Combining Income of Unmarried Co-Applicants Retention Period on Home Equity Loan Files RESPA Disclosures Given BEFORE Application Counteroffers and Denials on Dealer Apps Co-applicant vs. Co-signer "Customization" of HELOCs Adverse Action Notice for Credit Suspension? Loan Apps and CIP Changes Spousal Signature Requirements in Community Property State Solving the Mystery of Credit Scoring Models Tracking Marketing To Minority Groups Special Financing for Flood Victims Adverse Action Letters to Multiple Parties Inadvertent Monitoring Information Collection Record Retention on Prescreening Changes in Monitoring Information Collection Is an adverse action letter required when a counter offer is accepted? Adverse Action Guide? Adverse action for denial of ATM or debit cards? Fair Lending Policy: Reverse Redlining Issue Reg B Changes Roundup Guarantor Access To Borrower's Credit Scores OCC Changes Address? Limiting A Product To One Location Loan Guarantee By Spouse FCRA, Joint Accounts, and Adverse Action Commercial Loans: Customer Copy Of Appraisal Required? Retention of Loan Customer Driver's License Info Adverse Action Letters Under the New Reg B Auditing loan files Disclosure Requirements: Declining An ATM Card Does Reg B prohibit discrimination against an applicant who is involved in lawsuits? Adverse Action Notices: When And To Whom? Web Loans, Web Adverse Action Notices? Sharing Information From Co-applicants With Co-applicants Signatures: Love 'Em But Leave Them Off Of Loans Auditing loan files Regulations: Defining Application Evaluating Immigration Status in Lending Situations Can web applicants receive web adverse action notices? Unsecured Home Improvement Loans & HMDA Is there a retention requirement for notice of account denial? ECOA (Reg B) And The 30 Day "Notice Of Incomplete Application" Pricing Loans Based On Credit Scores Government Monitoring Information And Debt Consolidation Loans Credit Applications By Phone: Reg B & Determining The Application Date Refinancing, Government Information, and Reg B Appraisal Copies & Reg B 202.2(f) Application Requirements Can we ask a customer their marital status? Home Equity Loans & Collecting Government Monitoring Data Handling Repetitive Applicants Reg B Appraisal Notice Requirements Reg B Requirements: Appraisal Reports Targeting Customers For HELOC & Reg B Violations How many reasons do I have to give in a denial notice? Lending Disclosures at a Glance Counteroffers and Reg B Appraisal Right Notice on a Commercial Loan Social Security Offsets: Aren't overdraft fees extensions of credit? What about Reg B? Monitoring Collection Requirements Allowable Application Denial Co-applicant Adverse Action Notices Denying Credit To Permanent Resident Non-Citizens How Senior Is Senior? Collecting Loan Information Reg B, Adverse Action Notices, and Debit Cards Using Income From A Spouse For A Consumer Loan Refusing a Loan to Foreign Persons Validating a Credit Scoring System For collection purposes, what is the difference between a guarantor and co-borrower? Adverse Action Notices: Do we send them for withdrawn/incomplete applications? Question & Answer Question & Answer Adverse Action Letters & Guarantors Question & Answer FCRA, ECOA, and Adverse Action Notices Examiner's Notebook Don't Overlook The Common Violations Question & Answer Question & Answer Question & Answer Question & Answer Question & Answer Regulation B Changes Hit the Streets Proposed Changes to Regulation B Proposed Changes to the Official Staff Commentary Question & Answer Reg B Watch Out - Here Comes DOJ! Question & Answer Regulation B Proposals Something Old, Something New Question & Answer Question & Answer Question & Answer What's Ahead In Compliance Fair Lending, ECOA et al. ECOA & Reg B What is a Credit Scoring System? COMPLIANCE NOTES - Regulation B's Proposed Paperwork Burden COMPLIANCE NOTES - Getting the Spouse's Signature Can Be Asking For Trouble! Question & Answer COMPLIANCE NOTES - Reasons For Denial: What Works? FRB Issues Final Notification Forms Question & Answer Regulatory Simplification On The Prowl With Regulations B & C Question & Answer Fee Splitting Two Reg Tango? Question & Answers Question & Answer How Do I Audit For� Reg B Commercial Loan Applications And Reg B Question & Answer Question & Answer OCC Issues Guidance On Credit Scoring Question & Answer Question & Answer Final Rules From HUD And FRB On Self Testing Privilege EDITORIAL - Credit: Do Consumers Want It or Not? Question & Answer FRB Proposes New Adverse Action Notices Question & Answer Question & Answer Question & Answer The Regulation B Commentary Is Proposed Question & Answer Question & Answer Reg B: FRB Issues Regulation B Commentary Revisions Considering Age in Reverse Mortgage Programs Signatures: When not to Get Them Question & Answer Question & Answer Final Action on Monitoring Data Draft Model Comment Letter Reg B Commentary: Scoring Age Question & Answer Question & Answer FRB Proposes Rule on Self-Testing Question & Answer Tools, Tools, Tools EDITORIAL - Pre-approved Loans - Food for Thought. You're Never Too Old Reg. BB Regulation BB - Community Reinvestment Act CRA Ratings and Compliance Obtaining CRA Notices Quarterly CRA Reporting - Updated Income Levels CRA - Logging Company a Small Farm Loan? CRA Loans & HMDA Logs Earning CRA Services Credit CRA Public File - List for Branches CRA - Loan to Deposit Ratios CRA Branch Lobby Notice Only Current Customers Eligible for Credit? Earning Credit CRA Exam In Less Than Six Weeks Compliance Officer Also Serve as CRA Officer? CRA Branch Notice Requirements Posting the CRA Statement Developing a "Community Needs Assessment" How can I get more senior management support for my CRA program? Getting Management's Support for CRA Programs What can I do to get an "extra edge" for my next CRA exam? Key Factors Disclosure with CRA Model Reporting a Mortgage-Secured Letter of Credit Improving Residential Area in Bank's Town CRA: How Not to Change a Regulation Large Bank for CRA Purposes How to Make A Difference CRA Investment Test CRA Public Files Are We Looking At The Right Stuff? Penalty for HMDA, CRA Submission? Moving to large bank under CRA CRA/Fair Lending CRA Data Collection for New Businesses Officer Guidance Lines & CRA Do Not Confuse Income and Revenue Where can I find a listing of the new 5 digit Metropolitan Statistical Area/Metropolitan Division Area Codes? What is a Reportable CRA Loan? CRA Agreements Do Work New Institution: Starting a CRA File Looking For Sample CRA Statement Help From FDIC CRA in the Sunshine is Not CRA CRA Help From FTC Lending: Fannie Mae Exceeds LMI Goals A Ray of Sunshine for CRA? CRA Sunshine Quick Reference Question & Answer Consumer Advisory Council on CRA A Very Special Banker CRA and Subprime What Happens When Consumer Advocates Mean Well? CRA: Working "With" CRA and the CAC COMPLIANCE NOTES - CRA Sunshine Regs The Annual CRA Q&A Release Airing Opinions on CRA in the Sunshine COMPLIANCE NOTES - Saving a Strategic Plan COMPLIANCE NOTES - Meet the Service Test - With Post-purchase Counseling COMPLIANCE NOTES - Project Resources COMPLIANCE NOTES - CRA Wisdom. COMPLIANCE NOTES - Median Family Income 2000 COMPLIANCE NOTES - The CRA Rating Game COMPLIANCE NOTES - Non-Urban CRA Charter Schools and CRA Question & Answer Question & Answer Question & Answer Common Violations Floyd Flake's CRA Wisdom Question & Answer CRA in the Sunshine COMPLIANCE NOTES - OCC Publishes CRA Investment Directory COMPLIANCE NOTES - Seidman Calls On Neighborhood Groups COMPLIANCE NOTES - Homes for $1.00 COMPLIANCE NOTES - CRA: Federal v. State COMPLIANCE NOTES - CRA Tips CRA: Hawke Shows CRA Colors COMPLIANCE NOTES - 1999 Median Family Incomes EDITORIAL What's Wrong With CRA? COMPLIANCE NOTES - A Call For More CRA Data EDITORIAL Is CRA Headed in the Right Direction? Question & Answer CRA New Q&As for CRA Question & Answer CRA Service Customer Education Made Easy EDITORIAL - CRA And The Kennedy Legacy Question & Answer Question & Answer Question & Answer EDITORIAL - Playing Fair Question & Answer Building CRA Into Your Business Plan COMPLIANCE NOTES - Outstanding for Small Banks? NCUA's Membership Survey Question & Answer The Future For CRA What's Ahead In Compliance CRA: Continuous Evolution Question & Answer Mortgage Loans Hop On The TRAM COMPLIANCE NOTES - Privacy Training for Customers And We Wonder Why Customers Get Angry! Small Business Lending A Small Bank Niche? CRA Changing the Examination Paradigm COMPLIANCE NOTES - What Good Are Bad Loans? COMPLIANCE NOTES - Planning a Strategic Plan? COMPLIANCE NOTES - Making CRA Targets A Little Easier COMPLIANCE NOTES - Disasters Can Help Your CRA Rating COMPLIANCE NOTES - Free CRA Resources What Can You Do with CRA Data? COMPLIANCE NOTES - Strategic Plans for CRA? Question & Answer CRA's Investment Test Some Advice From The Pros COMPLIANCE NOTES - How Much Investment Opportunity Is There? COMPLIANCE NOTES - HUD Median Family Income Figures Out CRA - How To Pass The Investment Test Question & Answer Question & Answer Lending OCC Generates Small Business Lending Ideas COMPLIANCE NOTES - What is a Branch? COMPLIANCE NOTES - Looking for CRA Ideas? Putting CRA Performance Into Context COMPLIANCE NOTES - Satisfactory CRA Ratings COMPLIANCE NOTES - Politics of CRA COMPLIANCE NOTES - Getting Ideas for CRA CRA The Consumer Advisory Council Debates CRA COMPLIANCE NOTES - OTS's Seidman Calls for CRA Reg Review Question & Answer Question & Answer FDIC Joins RHP OCC Speaks Out On CRA Data COMPLIANCE NOTES - Native American Housing: CRA and Fair Lending Question & Answer COMPLIANCE NOTES - Rating CRA on the Internet Consumer Advisory Council COMPLIANCE NOTES - Rivlin Speaks Out on CRA EDITORIAL - It's Time To Start Counting The Cost Planning CRA Strategically Question & Answer Question & Answer Question & Answer What's Great About CRA? COMPLIANCE NOTES - CRA Ratings COMPLIANCE NOTES - FDIC Releases CRA Ratings Question & Answer CRA New Q& As EDITORIAL - The Constant Evolution of CRA: Regulatory Burden on the Move EDITORIAL - Credit: Do Consumers Want It or Not? Hot Tips From Regulators Question & Answer Preparing For The New CRA EDITORIAL - Assessing the new CRA Question & Answer CRA Examination Procedures Are Out CRA: Compliance Creeps Further Into Commercial Lending Question & Answer Question & Answer Question & Answer EXAMINER'S NOTEBOOK - CRA: Not as Easy as Pie CRA: Mid-year Check-up Strategic Plans: Are They Worth It? Experiencing the New CRA: That Performance Context Reg Y and the CRA Wars Question & Answer EDITORIAL - Pre-approved Loans - Food for Thought. The New "Burden Relief" Banking Act CRA/Fair Lending Examiner's Notebook: CRA Exams Can Be Pleasant! Question & Answer Reg. C Reg. C - Home Mortgage Disclosure Act HMDA Reporting Threshold HMDA Reporting � Bridge Loans HMDA � Loan Renewal/Increase on Rental Property Unsecured/Signature Loans - HMDA Reporting HMDA, GMI & Loans to Business Entities HMDA - Owner Occupancy Designation HMDA � Loan Renewal/Increase on Rental Property HMDA - Unaffixed Manufactured Homes HMDA/Gov Monitoring on Applicant & Co-signer HMDA Reporting - Permanent Financing HMDA - Data Reporting Owner Occupancy HMDA Re-file HMDA Reporting � Dwelling Used for Day Care HMDA � Which Date Do We Use? Revocable Living Trust & HMDA LAR Reporting Loan to LLC Sole Owner - HMDA or Purchase Money? HMDA � Loan Coded as Business/Residence Combo Commercial Loans � What�s HDMA Reportable? HMDA Reporting � Mixed Used Property Loan CRA Loans & HMDA Logs Loan Modification � HMDA Reportable? Owner Occupied Second Homes & Vacation Homes HMDA Reporting - No Written Pre-Approval Program HMDA Reporting - Closed-End Lines of Credit HMDA Log - Order Information is Entered HMDA Reporting - Modified Construction Loan HMDA Reporting - Swimming Pool Secured by Dwelling HMDA -- Changes to Pricing Information Reporting Oct 2008 HMDA - Double Reporting? Additional Funds to Complete Home Construction Loan Secured by Son's Home - HMDA Reportable? HMDA Reporting - Selling a Participation Loan Borrower Discontinues Loan Application HMDA Reporting on Entities Is the Assumption a Refi or Purchase Purpose Loan? Is This HELOC Renewal Considered a Refinance? Customer Refuses to Pay Escrow Reporting HMDA Data to the Board Reporting Non-Mortgage Loans under HMDA HMDA - Swimming Pool Loan Secured by Automobile FDIC Loan Definitions Cash Out Loan - HMDA Reporting HMDA Reporting - Multiple Advance Open Ended LOC HMDA Reporting - Home Purchase w/CD as Collateral HMDA Reporting - Office Isn't an Official Branch HMDA - Extending a Current Obligation HMDA - Non-Reportable Bridge Loan? HMDA Reporting - Loan Secured by Apartment Building Bridge Loans & HMDA Determining Income HMDA Reporting on a Commercial Line of Credit Hunting Camp - HMDA Reportable? HMDA Reporting - Commercial Loan Refinancing Automated Underwriting System - HMDA Reporting Collecting GMI on Loans Not Reported on HMDA LAR HMDA -Short Term Loan Refinanced for a Longer Term Reporting on an Application Withdrawn/Closed Loan HMDA - Define Temporary Financing Deceased Applicant - HMDA Reporting? P and I Payments - HMDA Reporting Reporting CD Secured Loan on the LAR Temporary or Permanent Financing? HMDA Reporting - Condo Association Improvements Asset Size - HMDA Reporting HMDA Triggering Loan CD Secured Loan & the LAR Fixed Equity Loans - HMDA Reporting Required? GMI Yi-Yi -Yi! HMDA Reporting - Opting Out HMDA Reporting - Reverse Mortgages HMDA - Unsecured Loan Used as Down Payment HMDA Reporting on Unsigned Loan Documents One Loan for Two Properties - HMDA Reporting HMDA Reporting on an In-house Renewal Acquisition & Merger - HMDA Reporting Requirements HMDA Reporting- Dwelling Being Converted to Office Home Equity Reported on the HMDA LAR? HMDA - Business Loan on a 1-4 Family Property HMDA - Rate Spread Reporting Mixed-use Property Rules - HMDA Reporting HMDA Reporting on an Unsecured Loan Commercial Loan - HMDA Reporting Credit Report Constitutes an Application? Farm Credit Loan Refinance - HMDA Reporting Determining HMDA Codes on Incomplete GMI GMI Collection on a Fixed Rate Home Equity Loan HMDA Reporting - Loan Application Correction No Lien Perfected on Property - HMDA Reporting? HMDA Reporting of a Home Improvement or Refinance Repurchased Loans Treated Like Bank Purchases? Dwelling Will Be Destroyed � HMDA Reporting HMDA Reporting - Mortgage on Vacant Land HMDA - Refinance of a Short Term Loan Loans Subject to HMDA HMDA Qualification HMDA - Motel Loan Pre-approval Confusion HMDA Filing Help Foreign Collection Item Hold HMDA - Optional & Non-Reportable Credit HMDA Reporting - Dollar Amount HMDA Reporting on Commercial Loans HMDA - Originating Institution HMDA Reporting on a Cash Out Refinance Loan HMDA Reporting - Short-term Loan for a Spec Home Mixed Use Property - HMDA Reportable? New Home Purchase - HMDA - Residential Property Loan Secured by CD We Don't Report HELOC's Under HMDA, However... Residential or Commercial? Cash Out Refinance HMDA -Second Applicant Considered a "Co-borrower"? RESPA Exemption for Interim Financing? Credit Life Financed on Home Loan, GMI Required? HMDA - Time Share Refinancing HMDA Reporting on a Term Loan HMDA - Better to Over Report than Under Report? HMDA Conundrum HMDA and the Reverse Mortgage Loan Reg E - Delaying Provisional Credit HMDA - Difference Between Prequalify & Preapprove What Income Do We Report for HMDA Purposes? HMDA Reporting on Refi of Home Improvement Loan HMDA - Definition of a Refinance Application Considered Pre-approval Under Reg C? Mobile Homes and HMDA Address to Include in HMDA Notice HMDA (PDF) Large Dollar Return Notification Is Home Equity 2nd HMDA Reportable? Definition of Temporary Financing Home Improvement Loan Secured by Vacant Lot Definition of Repeat Overdrafter Collecting GMI on a Construction Loan Are Internet Applications Like Mail Applications Temporary Financing Under Reg. C Government Monitoring Information Guru Compilation: HMDA (PDF) HMDA Refi vs. Modification Bank exec clears up Reg C�s gray areas HMDA Race & Visual Observation HMDA Rate Spread Reporting Occupancy on LAR, 2nd Home HMDA Rate Spread Determination Dates HMDA Borrower is a Trust Are We Looking At The Right Stuff? Is This HMDA Reportable Did HMDA Allow "NA" Entries Pre-2004 What "Note" Makes it HMDA Reportable The Masses Are Still Confused on Refinancings Penalty for HMDA, CRA Submission? Confusion Over HMDA Coverage HMDA Refi Test HMDA Reason for Denial HMDA Reportable Assisted Living Residence Who Should Certify HMDA Data Motel Loan HMDA Reportable? Posting the HMDA Notice for a New Reporter OCC Required Information, Mortgage Loans ARM Disclosure Results Interim Construction Inspections What Do We Really Get From Monitoring Data? HMDA Occupancy Code Non MSA Property Does a Fax Equal a Phone Call? HMDA Rate Spread Calc, - But Other Security Commercial Loan Now HMDA Reportable HMDA Home Improv. Reportable Prequals Under HMDA HMDA Revision of Definitions/Rules Do Commitment Letters qualify as a Preapproval? First Time HMDA Reporter Has Questions Temp Loan to Rehab Property: HMDA Reportable? When to Audit HMDA 2004 Information New HMDA Sign Reporting Small Dollar Withdrawn App HMDA Info on Brokered Loans Guru Chatter on HMDA/HOEPA HMDA: How Did HMDA Happen? Lien Status Reporting Under HMDA HMDA Reporting for Bank That Sells All Loans New HMDA Tools HMDA Help Definition of Multi-Family Dwelling HMDA Triggered by Pump Repair Loan? HMDA and Reporting Second Mortgages HMDA Reporting of Originated and Purchased Loans HMDA: Final HMDA Rules for 2004 Under the Revised HMDA Regs 2004 HMDA Reporting Checklist? HMDA Data Collection for 2003 Home Improvements, New Improvements, and HMDA Reporting Reg C, HOEPA, and Maturity Reporting Home Improvement Loans Non-HMDA Reporting Bank Required to Collect Data? Changes in Monitoring Information Collection What Do the Revisions to Regulation C Mean? Regulations: Defining Application Unsecured Home Improvement Loans & HMDA Using One Application For Checking, Savings, Cash Accounts & Loans Oh, Look! More C: FRB Expands HMDA Coverage Non-Reportable HMDA Loans Government Monitoring Information And Debt Consolidation Loans Reg C Relief Inconsistencies Between HMDA And The New Reg C Changes When HMDA Applies Reg C: Is there a definition of temporary financing? What Are The Upcoming Changes In Reg C / HMDA FRB Issues Proposal to Expand HMDA Reporting Specific Issues for Comment How to Comment Sample Reg C Comment Letter Loan to a Trust: HMDA Reporting Requirements Reinstated Applications: Practical Application of the HMDA Commentary Question & Answer Old Compliance Laws Never Go Away HMDA Exemptions Announced FRB Issues Proposal to Expand HMDA Reporting FRB To Review Regulation C Question & Answer Reg C Rule Final COMPLIANCE NOTES - Small Banks for HMDA COMPLIANCE NOTES - Another HMDA "Small" Rule COMPLIANCE NOTES - The Government's HMDA Software is Free COMPLIANCE NOTES - Congressmen for ECOA Data Collection And We Wonder Why Customers Get Angry! FRB Updates LAR for Y2K Regulatory Simplification On The Prowl With Regulations B & C COMPLIANCE NOTES - HMDA: The Cost of Non-Compliance Question & Answer COMPLIANCE NOTES - HMDA Small Bank Exemptions Question & Answer HMDA Data Use It Question & Answer HMDA Surfing Question & Answer COMPLIANCE NOTES - HMDA Tools COMPLIANCE NOTES - HMDA Exemption Size Grows COMPLIANCE NOTES - HMDA Help COMPLIANCE NOTES - Submitting HMDA Data Question & Answer How The FRB Uses HMDA Data For Fair Lending Question & Answer Tools, Tools, Tools Alert: The HMDA Commentary is Out! More On The HMDA Commentary Small Bank HMDA Exemptions Another FRB Proposal! Question & Answer Question & Answer Question & Answer Question & Answer Reg. CC Reg. CC - Expedited Funds Availability Act Reg CC Funds Availability Verbiage ATM Funds Availability Signage for Funds Transfer? New Account Deposit - Give Hold Notice? ATM Deposit Regulations Hold on Government Check Reg CC � Hold on Third Party Check No Large Return Notification Given Wired Funds � Funds Availability Remote Check Return Rules ATM Disclosures Case-by-case Hold Notice Check Hold on Part of a Deposit of Multiple Checks Reg CC � Banking Vs Business Days Return of Unauthorized Paper Debit Reg CC � Less Hold Time Reg CC � Insurance Draft Cashier's Check - Large Deposit Exception Hold Check 21 Disclosure - Return Deposited Items Substitute Check Disclosure Placing Longer Hold Due to Fraud Hold on Cashier's Check Deposited into Savings? Savings Accounts Funds Availability Disclosures Reg CC Signage & the Drive-Thru Window URCC Claims Operating in Agreement with Regulation CC Reg CC Hold Confusion Exception Holds on Treasurer or Bank Checks Unauthorized Items - 24 Hour Rule Reg CC - Holds on Local & Non-local Checks Reg CC- Three Years to Return a Forged Item? Only Drive-Thru Open Saturday - A Banking Day? Case by Case & Exception Holds - Definiton Needed ATM Deposits � Next Day Availability? Reg CC Signage Requirements Holding Checks - Member Notification Reg CC - Saturday a Banking Day? Endorsing & Signing Over a Treasury Check Holds on Credit Card Convenience Checks Offering E-Deposits - Compliance Issues? Reg CC Hold - Day Funds Become Available Multiple Deposits - Immediate Credit? Credit Card Convenience Checks & Midnight Deadline FDIC signs Returning an Unauthorized Paper Draft Hold Discussed w/Customer� Mailed Notice Required? Check 21 Substitute Check Policy Disclosure Night Depository Procedures ATM Fraud Reg CC - State Check Overseas Cashier's Check - Next Day Availability Is this an EFT? Insurance Draft and Check Policy & Procedures Does Check 21 & Image Exchange Preclude Reg CC? Cashier�s Checks & Next Day Availability Confused Over Reg CC's Standard & Extended Holds No Notice was Given on Large Item Return Exception Hold on Available Funds? HMDA - What Census Tract Info Do We Use? Reg CC & Tax Refund Checks Change in Branch Bank's Operating Hours Second Mortgage HMDA Reportable? Servicing Sold, Note Retained - Report Loans? Remotely Created Checks & Reg J Returning Unauthorized Remote Checks Guidelines Reg CC - Consumer and Commercial Accounts? Send Out Revised Hold Notices? Reg CC - Shorter Holds Reg CC Hold - New Account for Established Customer Deposits Under $5000 - Case by Case Holds Reg CC - Holding Funds on a Return Item Reg CC - Counting the Days..... Reg CC - Definition of New Account Cashier's Checks - Reg CC Stipulation? Reg CC Exception Hold - First $100 Reg CCDeclined - Notice of Action Required? Reg CC - Checks Issued by a Finance Company Reg CC - $100 Availability In Need of Funds Availability Clarification Reg CC & U.S. Banks Located Overseas Canadian Checks Subject to Reg CC? Hold on Cashier's Check Timeframe for Unauthorized Check Return Government Check - Funds Availability Cash Withdrawal Limitation - Funds Availability Authorization Implied? Disclosing Same Day Availability Large Return Notification on Returned Check? Redeposited Checks - Two to Four Day Return Time Frame Check Return Governed by UCC or Reg CC? Loan Disbursement Check - Next day availability Sending Items for Collection to Avoid Fraud Out of District Items Funds Availability on a New Account Hold Reg CC Hold on Escrow Check Check 21 Disclosures Commercial Internet Banking Validity of Claim on Remotely Created Check Check 21 Disclosure Notice Reg CC Holds - 2 Scenarios Remote Capture Policy Return of Unauthorized Pre-authorized Draft? Check Cashing - Hold Notice Hold Liability Reg CC & Traveler's Checks Teller Window Signage Holds on Canadian Checks Teller Station Hold Notice Verbiage Reg CC - Redeposit of Item Returned NSF Notifying Customer of Hold Reg CC & Savings Accounts Posting Funds Availability Policy Notice Non-notification of Large Return Item Debit Draft Form Hold on a Split Deposit Reg CC - Remotely Created Checks Remote Deposit Capture - Funds Availability Cashier's Check - Maximum Length of Hold Reg CC - Collected Balance Vs. Available Balance 2nd Business Day Hold -$100 Next Day Availability Reg CC's 24 Hour Rule Reg CC Sample Merchant Agreement Abbreviated Routing Numbers Reg CC - Disclosing Cut-off Time Change Deposit of Check with Ambiguous Payees A Resource to Refuse Claims from the Drawee Bank Difference Between "Special Deposit Tickets" & Deposit Tickets Is "Refer to Maker" Still the Last Resort? Returning an Unauthorized Telephone Check Reg CC Holds - Notification of Large Item Return Remote Deposit Capture - Funds Availability Money Grams & International Money Orders Reg CC 's Endorsements Printed in Black Ink Rule Time Limit for FRB to Return an Unauthorized Item Reg CC Changes & Remotely Created Checks Changing Reg CC Hold Verbiage Placing Holds on US Treasury Checks Recording Exception Holds Reg CC Disclosures for all Deposit Accounts? Placing a Hold on a Cashier's Check Next Day Availability on Rapid Refund Checks Placing a Hold on a Cashiers/Official Check Stop Payment on Interest Checks Case-by-Case Holds 5 Day Hold on Items Returned NSF Nightmare on Compliance Street Reg CC Hold on Deposit of Cash & Local Check Is Disclosure of the Routing Numbers Required? Is This Verbiage Required on Teller Receipts? Hold on Redeposited Local Check Over $5000 Reg CC (PDF) List of Regs Requiring Training Can't Provide Receipt Stating Funds Availability Plan to Close on Non-holiday-- Or Should We? Hold on Foreign Deposit Fed Helps Cancel Fraudulent Paper Drafts Reg. CC and Check Clearing Changes Redeposited Checks --- Duration of Hold Reg CC - Longer Extension of Exception Holds Compliance Signposts Disclosure of the Funds Availability Policy Training Page: Learning the Bank Numbering System Picking up and processing ATM deposits Changing Reg CC Hold Periods Required disclosures for new accounts Payable Through Check -- Local or Not? International Transaction and Late Returns Hold notice for pending chargebacks? Steps to Prove Check Kiting Payable Through Check -- Local or Not? Will the Closing of Fed Check Processing Sites Accelerate Funds Availability and Possible Exposure to Fraud? Bogus Cashier Check Warnings and Reg. CC I Changed My Mind Required Privacy Training Covering Required Training Subjects Holds on non-transaction accounts Failure to notify on large return item Check 21 Disclosures Who Sets the Amount of a Large Item Return Notice? Guru Compilation: Reg CC (PDF) Checks Drawn on a Correspondent "Do Not Write Below " Legend on Check Backs "Split Holds" Under Reg CC Reg CC - Next Day Funds Availability Float on Imaged Items Savings Funds Availability Reg. CC and Privacy Excuses for Non-Availability Reg. CC & $100 Availability on a Problem Account Reg. CC and Treasury Checks Hold on Checks Used to Purchase CD Limitations on Next Day Availability Meaning of P.E.G. EFT System and Automatic Holds Exception Holds and Call Verification Timing for Hold Notice Which Institution Holds the Bag on NSF Loss Reg CC Resources Resolving Business Debit Card Dispute Refusing to Accept Certain Kinds of Checks Old altered check problem Completing an Exception Hold Notice Form Late Returns Fine Points of Determining "Local" Check What Is YOUR Cut-Off Hour? Delayed Funds Availability for New Accounts Reg CC Large Item Exception Hold Return Item Notification Exception Holds for Next Day Availability Reg CC: When is an AccountConsidered "Open"? Business Check Card Regs Web Page Funds Availability Disclosures One Check, Split Deposit & Reg. CC Reg CC & Holds on Cash Deposits ATM Disclosures Regarding Fees And Availability ATM Cut Off Time Deposits, Reg CC, and Immediate Availability Options For Placing Holds On Large Overseas Checks Non-local Check Deposit & Wire Request Suspected Kiting, Returned Deposits, and Holds Reg CC, Extended Holds, and Notice Requirements Stopping A Kite With A Reg CC Hold Hold options for large, non-local checks Definition Of A Cashier's Check Holds On Credit Card Checks What is a "local" check? Reg CC: Previously Returned Unpaid Exception Hold Notification Of Change In Posting ATM Deposits Looking For Automated Reg CC Program Reg CC Disclosures, Cash Transactions, And Hold Status Are Official Checks and Cashier's Checks the Same? New Accounts & Notice Of Delayed Availability ATM Reg CC Disclosure Reg CC PowerPoint Presentation Responsibility For Large Item Return Regulatory Training Requirements: Every 18 Months? Reg CC: Giving Preferred Customers 'No Float' On Deposit Items Hold on savings deposit Reg CC & Credit Card Checks Tragedies and the Midnight Deadline - What Can You Do? Reg CC & The $100.00 Rule Case-By-Case Holds For Large Non-Local Checks Is the Reg CC notice of availability required to be posted on the window of drive-through teller station? Depository Bank Endorsement Requirements First $100 Already (More Than) Provided Reg CC: Restricting Access To The First $100 Reg CC Disclosures For New Accounts Signage For An ATM Reg CC Holds On Large Checks Reg CC: Does the "$100" Rule apply to each deposit, or to aggregated deposits? Availability Time Frames Counting Funds Availability Time Frames Holds on Credit Card Checks Reg CC: What time of day does a hold expire? Reg CC: Is there a limit to the number of reasons provided for an exception hold? Applicability of Reg CC Exception Holds On Deposited Checks Holds on Savings Accounts Savings Accounts & Reg CC Reg CC: Hold Notice Notification Requirements Reg CC and the use of "Refer to Maker" Reg CC & Depositary Bank ATM Deposits Interest On Uncollected Funds Check Fraud Losses & Exception Hold Policies Holds, Account Balances, and Reg CC Required Notice For Large Return Items A Comprehensive Approach to Reg CC Case-By-Case Holds, Exception Holds, and Overdraft Fees Location of Funds Availability Notices Reg CC & Suspense Accounts Reg CC, Savings Accounts, and Putting a Hold on Cash Same Day Settlement Process Refer to Maker Revisited Funds Availability Notice Requirements: Cutoff Hour Question & Answer Question & Answer Question & Answer Question & Answer Question & Answer Question & Answer Question & Answer Question & Answer Question & Answer What's Ahead In Compliance Regulations CC, DD, and Beyond EDITORIAL - Let Them Eat Cake! A Giant Step Against Check Fraud FED Considers Check Hold Changes Proposal Withdrawn On Reg CC COMPLIANCE NOTES - Does Reg CC Help? Question & Answer Reg CC What is Local? The Fed Reconsiders Question & Answer Question & Answer Expediting Compliance with Funds Availability Most Common Violations of Reg CC Question & Answer Question & Answer Question & Answer Question & Answer Expedited Funds Expediting Regulation CC Question & Answer Question & Answer Trouble Spots in Deposit Regulations When Are Deposited Funds Available? Question & Answer Question & Answer Supreme Court To Give Decision OnReg CC Cases Question & Answer Question & Answer Reg CC Amendment Passed Sign Here Please� Regulation Watch - EXAMINERS LOOKING CLOSER AT COMPLIANCE New Accounts & Reg CC Reg CC Changes Proposed "Excuse Me-What Was That Again?" Changes To Reg CC: Questions & Answers Reg CC "No Problem"-Who's Kidding Who?! Reg CC: "Funds Availability" Deadline Is Here! REG CC-Update Regulation CC & Return Items-It's Not Working Regulation CC Alert! Regulation CC Changes Coming Your Way Regulation CC�Down To The Wire� Reg. D Reg. D - Reserve Requirements of Depository Institutions Reg D Change � Effective Date Reg D Transfer Limitation Query Reg D - Do Fees Count Toward the Six Transfers? 0% Interest? Reg D Change - Updated TISA Disclosures Transfer Limit Change � Apply to Savings & MMAs? CD Penalty Vs CD Forfeiture Reg D Change for CUs and Banks? Complying with the Reg D Change Reg D Change for CUs and Banks? Questioning the Eligibility of Our NOW Accounts New Amendments to Reg D Reg D Transfer Limit Change Reg D - Transfer Violations Savings Account - Quarterly Transactions Government Entity Account � Earning Interest Reg D - MMAs Vs Savings Accounts Daily Monitoring System for Excessive Transactions Reg D � Allowing More than Six Withdrawals NOW Account for a Soccer Club Reg D � Excessive Withdrawals Checking Account to Checking Account OD Protection Reg D � Internal Transfer Loan Payments Banned from Opening MMA/Savings Account? Establishing a Sound Application Security Program Date of Deposit Causes Reg D Violation Reg D - Close Account Due to Excessive OD Activity Date of Deposit Causes Reg D Violation Reg D - Funds Transfer Within Accounts at Bank HSA Accounts & Reg D Transfer Limitations What About Reg D and Reserve Requirements? Additional Terms Triggered by the Word Bonus? Reg D Limits - One Owner Multiple MMDAs ACH Debits - Three or Six Limit? Passbook Savings Account Withdrawal Limit Reg D - Personal Statement Savings Accounts Reg D Limits -When is a Transaction a Transaction? Reg Q - Paying Interest during the Grace Period Western Union Transfer Subject to Reg D Limits Merchant Capture Device - Reg D Transaction Limits Communicating with MMDA Customers List of Reasons CD Penalties Must Be Waived Internal Transfers - Reg D Limitations Sample Excessive Withdrawal Letters/Notices Is There a Regulation Prohibiting...? Wire Transfers and Regulation D Car Dealer Reserve Account Reg D Withdrawal Limits Violation Reg D - Monthly PayPal Debit Transactions Reg D - Business MMDA Checks Made Out to Signers Reg D - Close or Reclassify the Account? CD APY - Monthly vs Quarterly Interest In Person Debit Transaction - Transfer Limitations Reg D - Internet Transfers from a MMDA to DDAs Transfers Subject to Reg D Transfer Limitation MMA - Transfers Between Accounts Sweeping Funds - Avoiding Transfer Limitations Reg D and an Interest on Demand CD Reg D - Notices of Excessive Transactions Reg D Transfer Limitation Confusion CD Penalty Reg D - Checks Payable to Third Parties Reg D Account Reserve Issues Reg D - Cashiers Check Payable to a Third Party Reg D - Deposit in Remote Deposit Capture Machine Short History of NOW and MMDA Accounts Savings Accts Reclassified as Transaction Accounts Reg D - ACH Transaction a Check or E-Transfer? Withdrawal of CD, Modified Terms Reg D Transfer & Withdrawal Limitations Letter How Should I Count These Transfers? Intent Behind Reg D ATM Withdrawals - Limited or Not? Notification of Excessive Transfers Can we Issue Debit Cards on Savings? Early Withdrawal Penalty on a CD Reg D - Savings Transfers & Withdrawal in Person MMA Internet Transactions Reg D & Internet Transfers Reg D - Corporate Sweep Account Taking Further Actions for Reg D Violations Restrictions Imposed for Withdrawal Limitations Credit Unions Offering NOW Accounts Business MMDA & Telephone Transfers Excessive Transactions - Charging a Fee Timeframe Before Opening New Savings or MMA? MMDA Closed Due to Excess Activity Contract Specified No Additional Deposits to CD Reg D - Possible Violation of Transfer Limitations When "Unauthorized" are Authorized -- What Then? Reasoning Behind Law Pertaining to NOW Accounts Refunding Fees Charged for Excessive Withdrawals Reg D - Managing Withdrawal Limitations Charged Back Check Count as 1 of the 6 Transfer/Withdrawals Limitations? Internet Banking and the Six Transaction Limit How Long Do We Track Reg D Violations? Exceeding Transfer Limits on Savings Accounts Regulations Re: Early Withdrawal Penalties on CDs MMDA Ownership Restrictions Disclosure of the Funds Availability Policy Reg D - Telephone & Internet Loan Pay Transfers Reg D Telephone-Initiated Transfer Count Toward the Transaction limit on MMDAs? Unlimited Amount of Savings Walk-in Withdrawals? Commercial DDAs and Interest IRA Withdrawals Before CD Maturity Reserves on deposit with the FRB Bank Courier Services and Excessive Transactions Regulation E Fee Disclosures - �205.7(b) Not a Withdrawal Penalty, a Prohibition Record Retention of Audits Restriction on Overdraft "From" Accounts Are Kiosk Savings Transactions Limited? Can a company that makes a profit hold a N.O.W. account? What is an ATS account? Interest on a DDA Fee Limit in Reg D? Reclassifying Savings with EFT Access Correct "From" Category for OD Protection Limited Withdrawal Disclosure CD renewal disclosures MMDA Commercial Activity Marketing IBAs to Municipalities Guru Compilation: Reg D(PDF) Time Deposit Penalties, What Is and Is Not "Work-Arounds" on MMDA Transaction Limitations Business Accounts Subject to Reg D Advertising a Stepped-Rate CD MMDA ATM Withdrawals Counting ACH Debits Toward the MMDA Limit Disclosures Required with ODP Product Three Strikes Rule for Excessive Transactions Wire Transfers and Reg D Online Banking Transfer Limits Online Transfers Under Reg D Reopening Account Closed for Reg D Violations Money Market Requirements Penalty For Early Withdrawal From CD Reg D: Converting To A Different Style Account For Excessive MMA Transactions Business DDA Accounts, Automated Transfers, and Overdraft Protection Are E-Banking Transactions Considered "In Person"? Reg D Limits & Check Withdrawal Phone Transactions Can a living trust have a NOW Account? Internet Transfers & MMDA Limitations Can we offer debit cards to savings accounts customers? Variations On NOW Accounts Trustees, Reg D, and Third Party Checks Reg D Non-Compliance: What's the penalty risk? Reg D - Excessive Use Reg D: Is a hospital considered a non profit organization? Money Market Accounts & Transfer Limitation Fees Reg D & Online Transfers Unlimited Automatic Transfers Under Reg D Toasters, Teddy Bears and Other Freebies Opening New Accounts Following Reg D Check Writing Violations Reg D: Unlimited Deposits to Business Savings Acct? Early Withdrawal Penalty Regulation? Home Banking and Reg D Transaction Limits IRAs, Older Customers, and Penalties Under Reg D Risks When Offering A Corporate Savings Account Regulation D, Transfers Of Funds: Do sweeps count against the transaction limit? Early Withdrawal Penalty Requirements For CDs Explaining Reg D Reg D: If a wire transfer request is delivered by messenger, does it count against the limit? Reg D: Unlimited Transfers for in-person transactions? ACH Debits, Merchant Bankcard Debits & Reg D Withdrawal Limits Reg D Explained Cash bonuses to open non-interest bearing accounts? Once a week transfer from savings to cover 'approved' overdraft. Can we do it? MMDA Transfers for Business Accounts Limit Raised? Question & Answer Question & Answers COMPLIANCE NOTES - What's So Interesting About Business Checking? Federal Reserve Responds to Reg D Questions Question & Answer Question & Answer Question & Answer Question & Answer Question & Answer FDIC Relaxes Rule Prohibiting Payment Of Interest On Demand Deposits Regulation D In 3-D: The 3-6 Rule To Count Or Not To Count�That Is The MMDA Question Examiner's Notebook FRB Proposes Revisions to Regulation D Question & Answer Question & Answer What's Ahead In Compliance Regulations CC, DD, and Beyond COMPLIANCE NOTES - It's Final: Regulation DD Change COMPLIANCE NOTES - Regulation DD: Changes to Lobby Signs and Disclosures Question & Answer Question & Answer Truth in Savings, Truth in Lending: Only Minor Changes Trouble Spots in Deposit Regulations Question & Answer Question & Answer Regulation Watch - EXAMINERS LOOKING CLOSER AT COMPLIANCE Reg. DD Reg. DD - Truth in Savings Passbook Savings � Rate Decrease Notification IRA Print Advertising Disclosures 0% Interest? Products & Rates - Web Page Disclosures Website Changes & Website Record Retention CD Renewal � Disclosures & Notices Dollar Amount Tolerance on Interest Payment Advertising APY Instead of Annual Percentage Yield Advertise a Tiered Rate Reg DD � 2008 Changes? Advertising Exemption Under Section 230.8 Radio/TV Ads for a Tiered Rate Account Advertising Free Checking for Life Being in Compliance with TISA TISA - Business Accounts Bounced E-statements - Rules/Practices Is a Gift a Bonus? Health Savings Account Ad New Reg DD Amendment � OD Fee Disclosures Recovering a Bonus for Early Closure Reg DD Changes? Regulation Q - Advertising TISA Disclosures Savings Accounts Funds Availability Disclosures Updating APR in Advertisements Format Requirement of E-Statements APY and Billboard Ad NSF Fee Change Notice Charitable Contributions Considered a Bonus? CD Changes � Notice to Customers Statement Considered an Advertisement? Outdoor Sign Reg DD Advertising "limited time offer" Only Drive-Thru Open Saturday - A Banking Day? Website Screen Record Retention Reg DD - Posting Fee Change in Branch Lobbies Bonus vs Interest Additional Terms Triggered by the Word Bonus? OD Fee Disclosures - Changing Order of Items Paid Changing Deposit Account Terms Bonuses received for "Free" Radio Ad and Tiered Rate Account Providing TISA Disclosures for Account Services Tier Advertising Bonuses received for "Free" Read Board Advertising CD Rate Oral Inquiries - Quote APY First? Reg Q Confusion & Competitor's New Account Promo Eliminating Float a Regulatory Requirement? Reg DD - Internet Ad MMDA advertising disclosure Tiered System Overdraft Fee Disclosures Wording on Billboard Advertising Reg DD & Advertising Overdraft Fee Increase - 30 Days Notice Required? New Account Promo - $25 Gift Card Bonus CD and Gift Electronic billboard advertising compliance Charging a Savings Account Overdraft Fee Advertising on Website "Click here" link... Website Changes & Website Record Retention Raising Wire Transfer Fees - New Disclosures? Reg DD & Introductory Rate Reg DD Bonuses Mailing Info on Bounce Protection Including Interest Rate & APY on CD Renewal Notice Advertising a Tiered-Rate Account Advertising Health Savings Accounts Free Checking Advertising - Inactive Account Fee Giving a Gift Card as a Deposit Premium Disclosure of OD Charges - Historical Exemption Click Here Link Rate Sheets - Are They Considered Advertisements? Understating an APY Gift Cards- disclosing fees on advertising Advertising on a Banner Reg Q Bonuses/Premiums & Bank Merger Deposit & Debit Charges on Free Checking? Fiduciary Accounts - Ownership & Disclosures Bounce Protection Fee Notification Outdoor Letter Board Advertising Guidance ATM Balance Information Bank Wants to Increase Fees, Disclosures Required? Free Checking - Account Closing Fee Trigger Term Lapel Pins? Tiered MMA Advertising OD Program - Disclosures and Notices Reg DD - Marketing of New Accounts Advertising Fee Free ATM Usage Advertising a CD APY on Scrolling Reader Boards Newspaper Ad - Additional Disclosures Required? IRA Lobby Poster Promo Service Charge Change Notice APY Disclosure of Promo Bonus Free Checking Account Inactivity Fee Time Deposit Advertising Disclosures Annual Percentage Yield Stated in CD Radio Ad Quoting CD Rates Over the Phone or in Person CD Promo Proposal Grand Opening Promotional Savings Account Free Checking? Direct Deposit/Minimum Balance Required Website Banner Advertisement Thirty Second Ad vs. Sixty Second Ad Totally Free Business Checking Account? CD Penalty Reg DD Compliance - Interest Payment APY vs Annual Percentage Rate Free Checking Advertisement eStatement Service Advertising and Overdrafts Reg DD Disclosure for "No Bounce Guarantee" Reg DD - Statement Printed After July 1st Deadline Annual Percentage Yield - Used First Refer a Friend Regulation DD Changes -- A Sleeper Issue? Commercial Account Overdraft Fees Premiums - Bonuses & Gifts Reg DD - Marketing of New Accounts Bonus Gift Card Reg DD Overdraft & NSF Fee Disclosures Advertising Promotional APYs on Deposit Products Reg DD Bonuses Language Disclosure for Sweepstakes Entry Blank No Need to Spell Out the APY in E-advertising? Reg DD - Properly Disclosing the Total Charges Reg DD - We Only Offer ODP for Sweep Accounts No ODP. Still Disclose the OD & NSF Fees? Disclosing Overdraft Balances on ATMs Renewing Odd-Term CDs into "Conforming" Terms Are We Advertising our Overdraft Service? Reg DD- Are Rate Sheets Advertisements? Is OD Privilege Signage Required on ATMs? TISA New Account Disclosure Error 30-Day Notice Given for Change in Tier Structure? CD Record Retention Reg DD Products - Minimum Dollar Amount Stated Overdraft Payment Programs and Reg DD Restrictions Imposed for Withdrawal Limitations TISA Rules for Automatically Renewable CDs Regulation DD -- ODP Resource Guide Changing Saving Withdrawal Fees Savings & Checking Account Inactivity Fees Reg DD - Garnishment & Levy Fees Sole Proprietorship Accounts & Reg DD Foreign ATM Usage on Free Checking Account Complying with Reg DD 30 Day Notice for Change in Product Tiers Mailing Info on Bounce Protection Calculating the APY for a Non - renewable CD Is a banner attached to building an exemption for a Reg DD ad? CD bonus adverstisement TISA Notice for Increased Fees State Interest Rate Before Yield, or Vice Versa? Youth Savings Account Offering Special Rate for CD - DDA Required Charging a Fee for Inactive Accounts Charging NSF Fees on Saving Accounts w/ACHs Posting Transactions Online in Lieu of Statements? Reg DD - CD APY Calculator Confusion Time Limit to Credit Unauthorized Drafts Accounts - Incorrectly Opened as Interest Bearing Restrictions on "Free" Business Checking Accounts Statement Frequency Required disclosures for new accounts Charging an Additional Fee for Difficult Deposits Statement in Ad Trigger Additional APY Disclosure Combining the TIN Certification Regulation E Fee Disclosures Compliance Tips for Advertising and Marketing Deposit Products Documenting Truth in Savings Compliance Fee Disclosed, But Never Imposed Posting Deposit Rates in the Lobby Tiered Rate Savings Ad on Scrolling Sign $50 for Direct Deposit & Funds Transfer Bonus Gift Card Disclosure of "call" feature in time deposit Celebrating Five Years in Business with 5 Yr. CD Reg. DD Fee Change Disclosure Changing CD Terms Limits and Reporting Promotional Gifts Steps in Changing the Fee for a Safe-Deposit Box Charging a Fee on a Completely Free Account Does this soccer promotion get a red card? Tiered rate CD disclosures Change of Terms Notice When Customer Requests Changes to IRA Accounts Disclosing Fee Changes APY When Customer Gets Monthly Interest Checks APY Disclosure Rules Is this a "Free" Account Is this a Lottery Check 21 to Improve Efficiency in Processing Statement Disclosure Requirements e-Delivery Disclosing Miscellaneous Fees Changing Deposit-Related Fees Opening Accounts by Phone Disclosing APY for CDs Triggering terms & disclosures Keeping Copies of Advertising Reg DD disclosures for Christmas Club AccountsOverriding lending policy Understanding "Change in Terms" Notice for Time Accounts When to Send Maturity Notices? Penalty For Early Withdrawal From CD Advertising APY Of Tiered Deposit Product New Account Opening: Is a check buy-back considered a "bonus"? MMA Interest, Tiered Rates, and Reg DD Using The Word "Free" In Advertising Online Banking: Is a paper statement required? Notification Requirements & Posting Periodic Statements On Web Site E-statement Regulations Increasing NSF Fees: Is a 30-Day Notice Required? Electronic Savings Account Regulations Overdraft Protection Fees Error Notification Responsibility Are we required to give an Account Agreement and Disclosure when giving a rate sheet to a customer? Offering Free Checks For New Accounts & Triggering The Bonus Exercise Caution in Disclosing "Bonus Rates" APYE Disclosure Reg DD and the Internet Account Opening Bonuses, Reg DD & Disclosures Truth in Savings Disclosures For Renewable CDs Explaining APY Account Changes, Disclosures & Missing Customers Guidelines for Fees and Charges Required Statements for CD Holders We're Merging: Advice For Change In Term Notices TIS Obligations and Restitution Non-compounding CDs, APR, & APY �And It's Not One Of The Worst IN THE NEWS - Regulation DD Commentary Stays "As-is" All Financial Institutions Now Have DD Checklist A: Account Disclosures: Content Checklist C: Advertising Checklist D: Calculations And Accrual/Payment Of Interest EDITORIAL - DD a Stunner FDIC Summary Of DD Examinations Question & Answer Question & Answer SPECIAL REG DD AUDIT EDITION - Auditing For Truth-In-Savings The ABC's of DD The Case Of The DD Paranoia Regulation DD Has Arrived� Reg. E Reg. E - Electronic Funds Transfer Lost/Stolen Debit Cards � Bank�s Liability Unauthorized Debit Card Purchases Reg E Change? Track EFT Inquiries Reg E & Provisional Credit The ATM in Spain Bank Address/Phone Info on E-statements Debit Card Denial Time Frame Canceled Online Transaction � Provisional Credit Stolen/Lost Debits � Reissue Disclosures? ATM Notice Removed Fraudulent Transactions � Card Owner's Liability ATM Non-customer Fee Disclosure Refusal to Close Debit Card � Bank Liability? Customer & Merchant Debit Card Dispute Replacement Card Conundrum A2A Statement Information EFT Agreements and Business Customers Case Law & Debit Card Owner Negligence EFT Procedures & Forms Reg E - Dispute Time Frame Sample Reg E Resolutions Letter Pinned Credit Card Transaction Dispute Reg E � Written Complaint Reg E Dispute - Arbitration Fees ATM Disclosures Hacked PC � Who Takes the Loss? Reg E � Customer/Merchant Dispute Reg. E - Errors on Closed Account Reg. E Dispute - Investigation Exceeds 90 Days PIN Guidelines Reg E Spreadsheet - Effective Transaction Date Preauthorized Now Unauthorized Debit Re-credit Phished Customer? Provisional Credit & the Questionable Customer Reg E - Periodic Statements Does a Chargeback = Provisional Credit? Waiver of ATM Fees Visa Logo on Debit Cards Equals Zero Liability? Reg E & ACH Disputes Differences Between EFT & Wire Transfers Joint Owners as POAs? Stop Pays Subject to Reg E Bounced E-statements - Rules/Practices Reg E � 10 Business Day Timeframe Merchant Refund Refusal PIN-Based Debit Card Dispute � Bank's Rights Reg E - Cardholder Liability & Merchant Chargeback E-Statement Authorization Reg E Provisional Credit vs Visa Provisional Credit No Longer Offering Business Credit Cards Reg E Explanations Needed Reg E, Rep Payee & the Dishonest Account Holder Reg E - Non-Fraud Protection? Amount of Cardholder's Liability Dispute Filing - Statute of Limitations Reg E � Definition of Point of Sale Transaction Reg E � Denying Disputes & Customer Notification Lowering the Card Limit Until Re-Issue Business Debit/Check Card Disclosures Reg E Provisional Credit for Closed Accounts Bogus Reg E Claim Foreign Bank Client - Claim Against Bank Unauthorized Item Disputed - What Do the Regs Say? ATM Withdrawals - Authorization Previously Allowed Debit Card Mailing � Age 70 & Over Excluded ATM � Disputing an Unauthorized Use Claim Unauthorized Card Use By Spouse ATM/Debit Card Applications Retention Reg E - Untimely Notice Stop Email & Paper Statements Per Customer Request Clarification on Paper & ACH Stop Payments Needed Access to Internet Banking Annual Privacy Statement Mailings Reg E Claim Time Frame E-Statement format change Error Resolution Investigation - No Fees Allowed? Waiting 7 Months to Dispute Card Transactions Merchant Replied Late � Claim Monies from Customer Reg E - Wires Cardholder Dispute Give Unsatisfied Customer Provisional Credit? Destruction of Card Verbiage Settling Reg E Claims Reversing a Premature Reg E Claim Stolen Card Registered on Verified by Visa Hotel Charge Disputed by Customer ACH & Reg E Unauthorized/Disputed ACH � Notice Required? Reg E & Unauthorized ACH Transfers Account to account transfers- covered under Reg E? Sending Customers Unsolicited Debit Cards Online Banking Deactivation Reg E Claim � Card Not Lost or Stolen Reg E - Non Resident Aliens Reg E - Final Resolution Letter Reg E POS Time Frame for Closing or Revoking Debit Cards Reg E, MasterCard Zero Liability & Bus Debit Cards Merchant Continues to Debit Customer's Account Mailed Returned - Block Card Access? Debit Card Charged for Hotel Repairs Auto Debit Loan Pay - Signature Required? Customer Merchant Dispute � Do We Take the Loss? MasterCard Error Resolution Notification Timeframe Reg E Claim - Customer Disputing Amount Charged Stolen Debit Card - Customer Liable for the $50? Revoking Transactions w/o Notifying Company Regs that Address Verbal Complaints Reg E Error - Counting the Days Reg E Error Resolution - Unauthorized ATM withdrawals Reg E - Overdraft Protection & Error Resolution Unauthorized Business Related Transaction E-sign Sign-up Form Reg E - Stop Pays on Preauthorized Transfers WSUPP Processing & Provisional Credit Unauthorized Charges - Visa Zero Liability Is this an EFT? Clarification on ACH Stop Pays & Revoking Payments Disputing an Internet Purchase Raising POS Limit - Give Reg E Notice of Change? Reg E - Interested Included in Customer Liability? Closing a Check Card Due to Inactivity Negligent Customer Disputing Charges Overdraft Fee Covered Under Reg E? Reg E - PIN & Non-PIN Cases Regulation Covering Internet Banking Bill Pay Reg E Coverage - Non-receipt of Goods Deposit Account Required for Loan Approval? Would These CDs be Subject to Reg E? Requiring e-statements on employee accounts Angry & Confused Over Reg E Debit Card for Sole Proprietor Reg E � Customer Disputing Merchant�s Charge Paper Statements for E-statement Customers Periodic Statement Transaction Information Business Debit Cards Linked to Personal Accounts Reg E - Obligated to Pay Fraudulent Dispute Claim? Debit Cards, Fraud & Reg E Consumer Liability Determined by Reg E or Visa? Debit Card Fraud - Provisional Credit Time Frame ACH Stop Payments Unauthorized Transactions - Police Report Required? Account Number on Hold Notices & Bank Statements ACH/Ebanking Reports & Records Retention Expired Debit Card - Stolen & Used Commercial Account unauthorized transactions Reg E Foreign ATM dispute Reg E Audit - Merchant Credit Services Reg E Applicable to HSA Debit Cards? e statements Customer's Recourse with Merchant Reg E - Temporary Reversal of OD/NSF Fees Parent's Debit Cards, Minors & Internet Purchases Unsatisfied Customers - Refunding Goods & Services Reg E Claim Denied on Friendly Fraud? HELOC Overdraft Protection VISA v. Reg E Reg E - Re-debit the Customer's Account? Reg E & HSAs Provisional Credit Predicament Foreign ATM Reg E Claim Reg E Problems Reg E - Non Receipt of Funds Corporate VISA Cards - Non-fraud Disputes Relative Given Debit Card by Customer Debit Card on Representative Payee Account Reg E - OD Fees & Provisional Credit Reg E Protection for Business Accounts? Reg E - Permanent Credit? Small Business Accounts - ATM &Check Cards Reg E - Recurring Service Cancelled by Customer Reg. E disclosure for online banking Time Frame for Checking Statements Credit Account for ODs from Lost ATM Card? Do We Follow Visa Rules or Reg E? Refund Included Provisional Credit Notice? Ordering Debit Cards - Signature Required? Reg E - Stolen Debit Card Electronic Right of Offset No Provisional Credit - No Real Proof Needed? Stolen Debit Card - PIN Written on Checkbook Amending Our Reg E Notices & Disclosures Reg E - Pending Item Reg E - Direct Deposit of Bank Employee Payroll Reg E. Problems Reg E & Non-resident Aliens Stopping an ACH Insurance Debit Asserting a Claim - Signed Notification Required? Fraudulent ATM Withdrawals - Provisional Credit Debit Card Disputes - Require Written Notice? Preauthorized EFTs & "Substantially Regular Intervals" ATM/Debit Card Suspension - Customer Notice E-Statements Reg E Dispute Outdated EFT Disclosure Open an Account if You Want a Loan? Debit Card Dispute Transaction Timeframe Stolen Debit Card - Dispute Denied Deny Provisional Credit? Reg E - Customer Liability for the $50.00 Rules for Business ATM Cards Deny Provisional Credit? ATM/Debit Card Agreement Can We Truncate Statement Account Numbers? Remote Capture Policy PIN Negligence - Customer Liability Reg E - Notice In lieu of Periodic Statements Written Statements and Reg E Errors Consumer Liability for Negligence in PIN-Handling Bank Wants to Increase Fees, Disclosures Required? European Vacation ATM Card Rip-off Reducing Error Resolution Time Frame Length of Time to Dispute Transaction EFT Check Collection Jail Bird's Hubby Used Her Debit Card Unauthorized Use of Prisoner's ATM Card Disputing Unauthorized Transactions at the Pump Reg E - Ebanking Wire Transfers Check Imaging & Reg E Compliance Issues Reg E Compliance for Beginning of 2007 Service Charge Change Notice Reg E Compliance Checking/Savings Statements Training on Reg E - Checks are Covered? Business Debit Card Liability Reg E - Statement Enclosures Reg E - Business Account Internet Transactions Reg E Guidelines & Online Bill Pay Error Resolution Reporting Originating Bank Returning/Reclaiming Funds Reg E & Business Visa Check Cards ATM Dispute Claim Fraudulent Check Card Transactions Reg E - Merchant Refund eStatement Service EFT - Once and Future Stop Pays Required Annual Disclosures Reg E and the Intoxicated Customer Reg E Claim Denied - Re-Evaluated for Bank Officer EFT - Visa - Line of Credit Reg E- Customer Claims Foreign ATM Kept the Cash Gas Pump Debit Card Charge Dilemma Customer Gave PIN Number to Family Member Sole Proprietorships & Reg E NACHA's Settlement Date or Reg E's Statement Date? Custodial Accounts and Regulation E � Consumer Accounts? Credit the Customer Without an Investigation? Reg E & Business Debit Card Protection Signed Access Device Request Customer Hasn't Checked Statement Since Nov 2005 Employees Required to Open Account at Other FI for Payroll Deposit Helping Customer Resolve Stolen ATM Card Issue Reg E & Possible Customer Negligence Business Account Debit Card Legal Issues Requiring Bank to Disclose a Fee from a 3rd Party Debit Card Fraud - Refunding Customer's Money Rules for Customers to Obtain Payroll Cards Customer's Negligence Voids Zero Liability? Customer's Time Limit on Unauthorized ACH Entries Customer Doesn't Want a Monthly Statement Compliance Issues of Stored Value Cards Phishing by Debit Card Provisional Credit for Multiple Transactions Unauthorized Use of Check Card & Customer liability Visa Debit Card ATM Fraud - Reg E or Visa Rules? New Reg E Rules on Check Conversions, Payroll Cards Prior Notice on Blocking Access to Debit/ATM Card Reg E & Business Check Cards Is Customer Responsible if PIN is on the Card? ATM, POS & "Checkless Account" Disclosures Unauthorized ATM Withdrawals in a Foreign Country CU Responsible for Member�s Loss to Phishing Scam? Reg E & the Consequences of Closing Accounts Insurance Company Bound to Reg E Disclosures? Unauthorized EFT - Bank Notified After 60 Days Customer Negligence and Reg E Posting Transactions Online in Lieu of Statements? Reg D Telephone-Initiated Transfer Difference Between POS and Debit Card Transaction Statement Frequency Bill pay stop order Checklist for Reg E error resolution Loan Interest Rate Discount for Automatic Tran Filing the Correct Report for Mysterious Debit Required disclosures for new accounts Recrediting account of fraud suspect ACH and UCC 4A Reg. E Error Resolution Notice Are Credit Unions Subject to Regulation E? Limiting Liability for Certain CCD Debits Disclosing Transaction Limitation Due to CIP Regulation E Fee Disclosures - �205.7(b) Bill Payment Fee Disclosure Regulation E Fee Disclosures Reg E - Debit Card for Trustees of Living Trust Reg E -Require a Filed Police Report from Customer Reg. E and CD Interest Transfers Reg. E, ACH, Visa Error Resolution Rules Identifying Accounts With Reg. E Activity Regulation E, Check Conversions, the ACH and Stop Payments IS eBill Payment by Check Covered by Reg. E? Debit Card Program for Businesses Is MasterCard SecureCode Subject to Reg. E Applicable Rules to ACH Stop Payments Credit Error, Now the Customer Wants to Keep It Notification of Check Conversion Possibilities Changing on-us check deposits to transfers Proposed Regulation E Amendments: Something for Everyone -- Or Not? Can Electronic Check Conversion Be Prevented? Does the Error Resolution Notice Change the Terms? Stop Payment Request: To Ask or Not to Ask Debit Card in Possession, is it a Valid Claim Are These "Errors" Under Reg. E Debit Card Liability New Debit Card, New Disclosure Sending Unsolicited Debit Cards Provisional Credit Days Under VISA Reg. E Fee Disclosure Breakdowns Recovering Reg. E Claims Amounts Paid Out When is a Business Day for Reg. E Is this an ACH transaction? Customer debit card dispute Reg. E Unauthorized Use & Had PIN Paying Interest on Disputed Amounts Statement Description Reg. E Liability - PIN on Card Reg. E Applicability Confusion Statement Disclosure Requirements Reg E Disclosure on Bank's Web Site ATM Surcharge signs Expiration Date on ATM Card De-activating a Customer's Internet Access Timeliness of EFT Claim and PD Report Positive Pay & Fraud NACHA & Business Accounts e-Delivery Disclosures Required with ODP Product Bank Liability When Customer Writes PIN on Card 60 Day Rule on Business EFTs? Gross Negligence and ATM Disputes Cardholder Liability for Negligence Stored Value Card Dollar Limit Reg E Coverage of Automatic Loan Payments What Falls Under the Term "Debit Card" Resolving Business Debit Card Dispute Ticking Clock on Reg E Claims Withholding Provisional Credit When Cardholder Fails to Report Refusing Oral Stop Payment Orders Our ATM, Foreign Card, Who Handles Claim? Skimming and ATM Losses Merger-Related Fee Changes Unauthorized EFT Claims Christmas Club Accounts and Reg E Reg E Disclosure Revisited Updating Reg E Disclosures Direct Deposit into Passbook Savings Forgery Affidavits & Electronically Processed Checks Reg E Disclosures on Web Page Savings Account Statement Frequency & Account Activity Credit Cards vs. Debit Cards: Disputed Transaction Time Frame Change in Reg E error resolution time frame? Denying Refunds for Unauthorized ATM Transactions Customer Involvement in Forgery Scam Sixty days to return paper draft? ATM Disclosures Regarding Fees And Availability Stop Payment On Check Card Transactions? Handling A Reg E Claim If The Claimant Dies Customer Liability on ACH and Reg E transactions Pre-paid debit cards --- stored value cards? Does Reg E Apply to Business Customers? ATM Signage Requirements Internet Banking: Reg E Disclosure Requirements Online Banking: Is a paper statement required? Reg E v. Visa: Who Wins? Refund on credit card subject to Reg E? Reg E: Is a sole proprietorship a natural person? Electronic Check Guide Available From FED STATUS OF ELECTRONIC CHECKING: We're Getting There! Notification Requirements & Posting Periodic Statements On Web Site Payment Stopped: Can payee issue ACH for the amount? E-statement Regulations Disputing Transactions On Check Card Reg E & Non-customers Reporting Lost ATM Cards Reducing Check Card Losses Reg E, Disputed Check Card Transaction, and Written Confirmation Error Resolution Timing Customer Gives ATM Card and Number to Co-worker: Is the financial institution responsible? Debit Card Disclosures For Commercial Customers Does Reg B prohibit discrimination against an applicant who is involved in lawsuits? What should you do when a family member steals a customer's ATM card? Does a business account fall under Reg E? Limiting Financial Institution ATM Withdrawal Liability By Contract Online Reg E Disclosures Electronic Savings Account Regulations Accessing HELOC Accounts: DDA Accounts, Debit v. Credit cards, and Unsolicited Delivery Reg E: Can we deviate from the model disclosures? ATM Surcharge Notice Mischief Notice Requirements For Time Deposits Error Notification Responsibility Reg E Error Resolution Disclosure Requirements Reg E: Online Bill Payment & Overdraft Responsibility Reg E Notification Requirements Can you avoid listing transfer limitations in Reg E disclosures? Home Equity Debit Card Withdrawals & Reg E Periodic Statement Requirements For Accounts Not Subject To EFTs Reg E Claims For Transactions Occuring Outside The United States What are the Reg E disclosure requirements regarding a merchant's use of electronic collection for checks presented for payment? Reg E & Zero Liability Forgery Claims: Time frame for re-crediting a customer Electronic Check Conversion And More: Are Your Reg. E Disclosures Current? Reg E & PC Account Transfers Periodic Statement Exception ATM Receipt: If the wrong address is printed, is this a violation? ACH, Reg E & Business Accounts Fees To Cover Reg E Compliance Error Resolution Notice: Definition of Business Day Reg E Notices: Which ones must be in writing? Reg E Debit Card Disclosure Reg E: Exclusion from coverage for smaller institutions? Reg E, Stored Value Cards, and Periodic Statements Reg E Redisclosure Requirement? Reg E Disclosures & VISA Check Cards Reg E Error Resolution and MMDAs New Reg E Disclosure? When to give the Reg E disclosure Reg E Final Rule Reg E Changes Reduce Error Notification for Signatures Account Statement Requirements for Commercial Accounts Can we send annual statement to low activity accounts? Reg E Timing Quiz How does the periodic statement apply to stored value cards? Question & Answer Update Proposed for Reg E Commentary Regulation E Proposal to Amend Regulation E on ATMs Question & Answer Regulation E Changes for 1999 Question & Answer Question & Answer New Time Frames for Reg E Error Correction Question & Answer Regulation E and the EBT Debate Reg E: To Pay Or Not To Pay Question & Answer Question & Answer Wire Transfer Regulation Is Good News! Reg E Claims�Reminder Reg. F Reg. F - Limitations on Interbank Liabilities Reg F Requirements Adequate Capitalization of Correspondents Reg. FF Regulation FF - Obtaining and Using Medical Information in Connection with Credit Compliance with Reg FF Reg. GG Regulation GG - Prohibition on Funding of Unlawful Internet Gambling Complying with Reg GG Reg. H Regulation H - Membership of State Banking Institutions in The Federal Reserve System Calculating the LTV Training Requirements for Security Officers Required Annual Employee Security Training Purpose of Changing Bait Money Security Camera Requirements Panic & Alarm Buttons Is there a bait money requirement? Bank Protection Act Information Presenting Annual Security Reports To The Board Making a Significant Change? Reg H Disclosure Requirements Question & Answer Reg. J Reg. J - Check Collection and Funds Transfer Giving Reg J Notification After Late Return Remotely Created Checks & Reg J Question & Answer Reg. M Reg. M - Consumer Leasing COMPLIANCE NOTES - FRB Issues Technical Changes to Leasing FRB Offers Consumer Education Tool COMPLIANCE NOTES - FRB Proposes Revisions to Consumer Leasing Reg. O Reg. O - Loans by Member Banks to Their Executive Officers, Directors, and Principal Shareholders Reg O - Loan to a Director's Company Compliance with Reg O Reg O � Overdrawn Director's Account EVP Covers Son's OD - Reg O Violation? Reg O Q & A Follow Up Reg O � Holding Co Officer an Insider Reg O � Loan Payment Date Change Reg O - NSF Fee Refund Reg O � Sold Loans Reg O � Insider�s Shares Reg O � Overdrafts & Related Interests Reg O & Executive Officer Account Signer Reg O � Senior Management Employee Benefits Reg O - Bank Holding Company Chairman Deposit Products & Insiders Credit Verification Retention Loan to Company - Director is Shareholder Loan to Entity - Demand Clause Required Reg O Reporting - Standby Letter of Credit Reg O � Participation in Major Policy Making Became EO After Obtaining Loan � Reg O Violation? Dedicated Regulation O Officer Reg O - Extensions of Credit in the Aggregate Waive Wire Transfer Fee - Reg O Violation? Reg O - EO Signer on Overdrafted Account Reg O - Aggregate Lending Limit Regulation O - Overdrafts on Insider Accounts Insider Lending - Language in the Note Executive Officer's Loan - Demand Clause Required? EO Signer on Various Accounts Reg O - Defined Marketable Collateral BOD's Loan Modification Reg O - SBA Loan Reg O - Waiving the 1% Origination Fee Reg O - Bancshares as Collateral Executive Officers & Extensions of Credit Reg O - Loans to Immediate Family Reg O Overdraft Provisions Reg O - Readily Marketable Collateral Reg O - Keep Names Private? Executive Officer/Director Overdraft Limits Paying Director's Uncollected Funds Check, No Fee Reg O - Executive Officer's Repeated Overdrafts Bank Employee Overdraft Reg O Overdraft Limitations Reg O - Board Approved Revolving Line of Credit Loan Reporting, Guru Follow Up Is Reg O Retroactive? Reg O � The Director Isn�t the Borrower, but ... Reg O - Credit Card Extensions of $15,000 or Less Reg O Limits & Corporate Credit Cards Reg O - Single Insider Aggregate Lending Limit Reg O or the Applicable Reg Offering Insiders HELOCs with No Closing Costs Reg O - Recordkeeping of Insider's Family Members Ex Officer Reporting Loans from other Banks LLC Acct Overdrawn By Director, Reg O Violation? Is the Loan to spouse, a Loan to Ex. Officer, too? Reg O & Payment of Employee Overdrafts Reg O (PDF) Accounts Subject to or Excluded from Reg O? Demand Feature Provision Applicable to Directors? Waiving the Overdraft Fee - Director is Signer Insider Report Requirement on Guaranty? Reg O: Waive Service Charge for Excess Withdrawals Does Reg O Apply to Loans on the Secondary Market? Reg O Applying to Foreign Bank Branch in the U.S. Is Reg O Just for the Borrower? Reg O - Mortgage Loans Sold to Investors Fine points of Reg O Reg O and minority partnership interests Reg. O Demand Clause - Loan Secured by Deposits Reg. O Loan Limit Exemption Preferential Employee Loan Rates Mortgage Rates Tied to an Employee Benefit Plan Prohibiting Benefits for Good (Director) Customers Reg O and Overdraft Fees (Not) Charged Reg O and Discounted Loans Employee Loan Program What Reg 0 amount to report? Guru Chatter on Reg O (PDF) Clarification Sought on Reg O Overdraft Provision Reg O Exemptions Waiving Service Charges for Directors Employee Overdrafts Demand Feature for Executive Officers Reg O Demand Clause Ethics, Banking, and the Rest of Corporate America Does Reg O Allow Waiver of a Director's Late Fee? What is the definition of "unimpaired capital"? CDs, Collateral, Insiders & Reg O Insider Lending Limits & Mortgages Lowering Intrest Rates For Executive Officers Reg O and Arm's Length Transactions Reg O: If a loan is made to a spouse, under their own signature and taxpayer ID, is it an insider loan? Does Reg O apply to the spouse of an executive officer? Prior Board Approval under Reg O Reg O: Financing The Sale Of Land Owned By An Executive Officer Does Reg O apply also to the spouses? Reg O And Executive Loans From Affiliates Required Forms For Reg O Compliance: What do directors and executives need to sign? Reg O, 0% Interest Loans, and Checking Account Lines of Credit Reg O: Annual Board Approval For Executive Lines Of Credit? Reporting The Extension Of Credit Reg O in a Box Directors As Guarantors COMPLIANCE NOTES - Indebtedness Reports - In the Mail Question & Answers Reg O Final Reg O Regs Why Comment? The Numbers on Reg O Guidance for Directors Reg O: Action on O Question & Answer Changes to Regulation O Question & Answer Reg. P Reg. P - Privacy of Consumer Financial Information Joint Marketing Agreements Sending Out Privacy Notices in Statements Truncating Bank Receipts California Financial Privacy Information Act (CFIPA) Charged Off Accounts - Annual Privacy Notices Opt-out Disclosure Required? Bank Info Required on Privacy Notices? Is Reg P Applicable to DBA Accounts? Privacy Laws & Marketing to Non-Customers Reg P Annual Vendor Review Is a Privacy Notice Required for Loan Guarantor? Sharing Kiting Info with the Other FI Verifying Checks Over the Phone Required disclosures for new accounts "Yes, That Check Will Clear," Violating the USAPA? How Much Can Privacy Statement Change w/o Notice? Disclosure of Confidential Customer Information GLBA agreement with third parties Privacy Training Presenting Annual Security Reports To The Board Must Privacy Notice Be Posted On ATMs? Privacy Notices To E-Customers Reg. Q Reg. Q - Prohibition Against The Payment of Interest on Demand Deposits Free Business Checking Account Compliance Refer a Friend Regulation Q - Advertising Reg Q Premium Restrictions Will Promo Open a Treasure Chest or Can of Worms? Giving a $50 Certificate to 18 Year Olds Reg D � Excessive Withdrawals Bonus vs Interest Shredding the Competition Additional Terms Triggered by the Word Bonus? Bonuses received for "Free" Bonuses received for "Free" Reg Q - Cash Bonuses for Opening Accounts NOW Accounts Vs. Demand Deposit Accounts Mail/Telemarketing Campaign - Gas Card Giveaway $100 for Opening an Account with Direct Deposit Reg Q Confusion & Competitor's New Account Promo Reg Q - Paying Interest during the Grace Period New Account Promo - Regulations Triggered? Bonuses on an Account $25 Gift and DD Account Giving a Gift Card as a Deposit Premium Bonuses on an account Reg Q Bonuses/Premiums & Bank Merger Paying Interest on a DDA Debit Card or Online Bill Pay & the Bonus Rule Bonus Bucks Reg Q - Paying Interest on a DDA Account Premiums - Bonuses & Gifts Reg Q - Cash Incentives to Open a Checking Account Give Aways and Drawings Two Reg Q Questions Accounts - Incorrectly Opened as Interest Bearing Commer