Support for BOL is provided by:

MAIN CONTENT

Compliance

Agency Road Maps

Alphabet Soup

Compliance Tools

FACTA/FCRA

OFAC

Lending

FACTA/FCRA

Lending Tools

SCRA

Marketing

Operations

Check 21

Operations Tools

SAR Resrch Guide

Security

AML/BSA

Bank Robbery

Counterfeits

ID Fraud/Phishing

Security Tools

Technology/eBanking

Info Security

SPECIAL AREAS

BOL Archives

BOL Blogs

Briefing Archive

Calendar

Court Watch
Em@il Education

Examiner's Corner

Executive Briefing

Infovault

Launch Pad

Site Map

Site Orientation

Top Stories

~ ~ ~

SERVICES

CrimeDex

Em@il Education

ID Verification

Record Retention

~ ~ ~

SHOP

Banker Store
Bankers Info Ntwk
Vendor Connect

CONNECT

Career Connect

Learning Connect

Vendor Connect

Guru Central

INTERACT

Ask a Guru
Bankers Threads

Contact Us

Give Us Feedback

TOOLS

60 Second Solutions

Alphabet Soup

Banker Tools

BOL Forms

FUN

BOL Recipes

eCard Exchange

LEARN MORE

About Advertising

About Our Sponsors

About Us


Real Estate Lending Record Keeping Record Retention Referral Refinancing Reg AA Reg B Reg BB Reg C Reg CC Reg D Reg DD Reg E Reg F Reg H Reg J Reg M Reg O Reg P Reg Q 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 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 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 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 Referral 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 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 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 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