Vendor Guru Q&A - Compliance

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Latest Compliance - Board of Directors Topics

What does my regulator's request mean?

10/30/2016

What does our regulator mean by "most recent report for SAR /CTR filed along with 3 years filing trend"?

Who do we have to train on BSA and how often?

07/03/2016

Who do we have to train on BSA and how often?

"Checklist" to Use in Compliance

12/12/2015

Is there a "checklist" to use in compliance that would list the things for each regulation that need to be completed each year? For example, annual training, reports required board notifications, etc.

Corp Board Appoint New Signer if Only One Deceased

01/07/2013

If there is only one signer on a corporate account and he passes away, can the corporation's board of directors appoint a new signer?

Business Purpose Medical Marijuana-Legal?

10/08/2012

I have a possible prospect that would like to open a business account here and he has his business license and EIN number. The purpose of the business is Medical-marijuana dispensaries. We are a community bank and I want to know if it is legal to even open in the state of WA. I understand it is legal to have these dispensaries in the state of WA, will we be in compliance?

Board/Executive Officers Exempt from OD Safeguard?

06/18/2012

Are board of directors and executive officers exempt from having Overdraft safeguard? What if they are listed in a non-owner relationship in a deposit account?

Waiving Overdraft Fees for Board of Directors

09/12/2011

During our annual internal audit of Reg. O, we discovered that overdraft fees are being waived for the board of directors. The overdrafts were under $1,000 and the account was not consecutively overdrawn for 5 days or more. At first, we felt that we could defend this by proving that our BOD is in similar circumstances as other depositors that we waive overdraft fees for. Management has decided that proving these "similar circumstances" may not be a risk we want to take with examiners. How should we handle this violation? Should we have the board members that are in violation pay the fees that were waived? Or should we implement training and awareness to ensure this violation does not happen again?

Extended Due Date on Loan for Director (Reg O)

08/29/2011

A director (reg o) has a loan. Can the due date be extended each year without board approval with the same interest rate? This loan started in 2007 and each year the due date has been changed for another year. The loan is an unsecured loan for 25,000. Also, this director has another unsecured loan for 5,000 with the same thing happening.

Printable Guidelines for Cashing Business Checks

08/15/2011

I have a customer who is the sole member of a corporation. He has been told by his attorney and accountant that he can cash a check made payable to the corporation. This is not our bank's practice. Can you direct me to something printable to give to my customer stating guidelines for cashing business checks?

Responsibilities for In-House Auditor?

04/25/2011

What are the responsibilities for an In-House Auditor? Our auditor considers daily activity of the employees as an auditor responsibility.

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UDAAP: The CFPB’s First Case

In its first significant enforcement action, the Consumer Financial Protection Bureau has issued a consent order against Capital One Bank.

BSA Enforcement Hits Royal Bank of Scotland

As many foreign banks doing business in the United States have discovered, it is not enough to import the compliance systems used in the home country. When in the USA, do as the USA requires.

Real Estate Loan-Property Owner Is Trust Scenario

03/17/2019

Our borrower is an individual. The purpose of the loan is refinancing a first lien with another lender. The property owner is Trust. Is this acceptable and do you have any recommendations for dealing with this scenario?

Flood for Condo-No Replacement Cost on Building

03/17/2019

The maximum amount of flood insurance that can be purchased on a condo is 80% of the replacement cost of the building or the total number of units in the condo building times $250,000, whichever is less. What if there is no documented Replacement cost on the building, should we use the appraisal value as the basis of our calculation?

Bridge LE: Expedite w/ Investment Acct./TRID Loan

03/17/2019

We issued a Loan Estimate for a bridge loan to purchase a home to be secured with the purchased property and the applicant's current residence. Due to timing circumstances with the applicant and the sellers, the applicant now wants to expedite the purchase by using an investment account and use the TRID loan to get reimbursed. Can I use the same application and re-disclose the LE as a refinance or home equity purpose?

Credit Score Disclosure Exception Notice

03/10/2019

We recently switched credit bureau vendors. This vendor automatically includes the credit score disclosure exception notice with the credit report. We in turn provide this disclosures to those who apply for consumer credit. There are times when a lender will use a consumer report for a business purpose loan. If we provide the credit score disclosure exception notice on a business purpose transaction/application are we asking for trouble with examiners? Could we be subject to fines?

Add Force Placed to Nonaccrual Collateralized?

03/10/2019

Can you add force placed insurance to a non-accrual loan that is well collateralized? State laws and the contract allow it for it.

Latest Compliance - Board of Directors Topics

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