My bank is a small creditor who makes HPMLs. We’ve been claiming the escrow exemption, but now I’m not so sure we should. Sometimes we set up accommodation escrows for extenuating circumstances – does that cause problems?
What is not in the proposal that we need?
I have a question on the new Reg CC update, specifically, on the large check deposit. I have a customer depositing a out of town check made to himself in the amount of $106,000. How do I handle this? Example: 2-12-2020: Place a Large Deposit Exception hold on the check making $200 available 2-13-2020, $4,800 available 2-14-2020 & $101,000 available 2-24-2020. So would the new amounts be $225 available 2-13-2020 and $5,300 (to make a total available $5,525) available 2-24-2020 and the rest available 2-24-2020?
What is the Grace Period for the Community Bank Leverage Ratio (CBLR) Framework?
Our bank currently does not open accounts for Non-Resident Aliens (NRA). I have a new customer that has an ITIN for work only, and a work authorization that will expire at the end of the year. She says that she is a "permanent resident" but does not have a permanent resident card. She says that this Employment Authorization Document (EAD) is her "green card" and is the same thing as a "permanent resident" card. Do I need to worry with it, or just take her word and move on?