Vendor Guru Q&A - Compliance

Latest Compliance - Article 9 Topics

Certificate of Deposit from other Banks-Collateral

08/06/2012

A customer wants to pledge Certificates of Deposits from other banks as collateral for a loan at our bank. Where do I find forms and what are disclosures? $100,000 10years monthly payments set up like a mortgage payment.

What are Consumer Goods for Art. 9?

10/04/2004

Under the revised Article 9, we are required to terminate the UCC on consumer goods when the debt is satisfied. What is the definition of consumer goods?

RA9, Continuation, And The Need For An Initial Filing Statement

07/15/2002

I noted on your Roadmap that you indicated a transaction subject to RA9, with security interested perfected under old A9, perfected by filing, in the correct state, with the correct filing, should be continued prior to the normal lapse date by an initial financing statement. I was under the impression that a correctly filed security interest subject to a UCC1 filing under old A9 that meets all the requirements of RA9 should be continued by virtue of a UCC-3 continuation within the window period prior to the normal lapse date, not by an initial filing statement. Please clarify the need for an initial filing statement. Up to this point, I had understood that the initial filing statement was the means to maintain your lien position at the same time you were "correcting" or bringing into compliance with RA9 a filing not meeting the requirements of RA9, but for which you had been perfected under prior A9.

Handling A UCC Release

12/03/2001

Does the bank have to record the release of a UCC, or is it sufficient to sign the release and give it to the customer and let them deal with it?

Continuation: Clarification on the Filing Requirements

05/07/2001

Can I get a clarification on the filing requirements under the new article for a continuation. I was under the impression that if a continuation was filed PRIOR to the July 1st effective date that it would be filled in accordance with the current Article 9 rules and that it would be effective. Basically, do we have to file an "in lieu" financing statement prior to the effective date or do we file the same way we have in the past?

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Copying ID Documents

Question: I represent an unregulated lending entity which is a wholly owned subsidiary of a large cooperative. We lend (indirectly) in approximately 20 states.

Church/Credit Union: Non-government Organizations?

08/01/2021

We are going back and forth as to whether or not a credit union or a church are actually considered non-government organizations? Although we know that they are non-profit, I have read conflicting information and am trying to settle this internally.

Record Retention for Debit Card Dispute Docs

08/01/2021

How long do we need to keep debit card dispute docs? (What is the time of retention?)

Advertising-more than ECOA, TILA, TISA and Fair Housing

08/01/2021

Is following the standard Regs, B, Z, DD and fair housing going to ensure advertising compliance?

Handling Reg E claims on older transactions.

07/25/2021

If an EFT claim is made long after the statement is sent showing the transaction, the rules of investigation don't apply. So why do we investigate any of these claims?

Compliance Info on Paper Checks

07/25/2021

I was wondering if you could point me in the right direction as to where to find more information on compliance for paper checks? Whenever I place a stop payment on a paper check, there's a disclosure that says "this request will expire in 6 months in order to comply with regulatory requirements." For the customers who ask for a more in-depth answer, what can I tell them?

Latest Compliance - Article 9 Topics

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