We often have lobby posters advertising products, services, benefits like trips on a discounted price and others things on display so staff can answer questions on these and to promote these items. Do they require the general FDIC advertising statement>
Is use of a general AAN turndown reason such as: “Unqualified co-applicant” considered specific enough for Reg. B compliance or should a general turndown reason like this be avoided?
Was wondering if bankers can provide examples of what is allowed to be provided to their customers when they close accounts due to AML, Legal or Adverse Media concerns.
Is an adverse action required to send to a customer if the bank force closes the customer's checking account?
As an FDIC regulated institution I wanted to inquire about notification requirements regarding adverse action. I am unsure if I am reading the regulation accurately in stating that Oral Notification by small-volume creditors is a loop hole to not having to issue a written adverse action notice. We definitely have less than 150 applications. Please advise.
Do we give an adverse action notices when we turn down an account?
Where can I find the regulation that states if a lender denies a loan application, the loan applicant must wait 30 days before reapplying?
If a borrower was denied credit for insufficient income (non credit score related),
does the credit /score disclosure need to be included with the denial letter?
Do the ECOA/Regulation B requirements around incomplete applications (12 CFR 1002.9(c)) apply to business credit applicants?
In a QC HMDA audit 2014 it was found that the action taken was inaccurate after the borrower was sent a withdrawn letter. It should have been declined. (ECOA Violation noted) The loan was not reported on HMDA LAR in 2014 due to the AA letter being prepared in March of 2015. The date of AA letter is what is used for reporting. Can this HMDA loan still be reported in 2015 using the date of the now final action taken of AA letter?