Most Popular Compliance Content
Adding Owners CDs
01/29/2023
We have a CD that the customer wants to add a joint owner to in mid-term of the CD. I am thinking we should issue in lieu of since we are technically changing ownership. Others think we should just re-write the CD adding the joint owner while keeping everything else the same. What is your recommendation and why?
Reg CC Holds on Treasury Checks
01/29/2023
Can a US Treasury check be placed on a funds availability hold and for how long?
Freezing Future Deposits Upon Notice
01/29/2023
If an account doesn't have the entire amount specified in a "Notice of Freeze" and in this case it is from the Florida Department of Revenue, do we hold just what is in the account the day we receive the notice, or do we place a hold on the account for the entire amount of the notice thereby holding all future deposits up to the hold amount? (The Florida DOR collects taxes and child support.)
State Law and HMDA Categories
01/22/2023
I have a general question about Texas Home Equity law and HMDA reporting. If under Texas law, a home equity loan is considered a refinancing or cash out refinancing regardless of whether the new loan satisfies an existing dwelling secured debt, can that be reported as a refinancing or cash out refinancing on the HMDA LAR? To my understanding, state law does not impact the reporting of loan purpose under HMDA rules. If a new loan does not satisfy an existing dwelling secured debt, should it be reported as refinancing or cash out refinancing? I’m specifically referring to the Texas A6 Home Equity loan product. Under Texas law, this product is always classified as refinancing or cash out refinancing regardless of any other definition of refinance.
Reg CC Holds on Treasury Checks
01/22/2023
Can a US Treasury check be placed on a funds availability hold and for how long?