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Sample Copy of Due Demand Clause for Reg O

04/02/2012

Do you have a sample copy of the due demand clause for Reg O? We have FDIC examinations and run a good bank, but they say we should have an executive officer sign the due demand clause.

Gross Income for Loan Applicants

10/18/2010

We qualify loan applicants based on gross income. Our credit officer says that tax free income from SSI or VA Disability is the gross income and shouldn't be grossed up. I say the income is net and should be. Who's right? If we don't gross tax SSI up, are we discriminating?

HOAs & the USA Patriot Act

03/31/2008

An issue has arisen at my bank concerning the need for a signatory on a homeowners association account to submit his social security number. My bank's BSA Officer believes that he must do so. I am not so sure. This individual has no personal accounts with our bank, but is listed as a signatory on two accounts dealing with homeowner's associations. The person in question refuses to give his social security number. How are HOAs classified for purposes of the USA Patriot Act? It's my understanding that the HOA is the owner of the account. I know that the signatory situation was in the proposed rules, but not the final ones. I would appreciate it if someone could provide me with some guidance.

The Risk Focused Examination

12/01/2005

In times past, examiners used checklists to conduct examinations. Each regulation had a checklist and the examiner worked through the checklist.

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EGRRCPA Extends Exam Cycle

by Patti Joyner Blenden

Responsible Enforcement: The CFPB's Position

On June 25, 2013, the Consumer Financial Protection Bureau published Bulletin 2013-06 in which it described its approach to enforcement and expectations of responsible business conduct.

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Small creditor escrow exemption SNAFU

08/02/2020

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?

New Reg CC Update - Large Check Deposit

08/02/2020

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?

Flood Q&As, what’s up?

07/26/2020

What’s happening to the flood Q&A, will it be incorporated into the regulations?

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