We disclosed a PTIL to refinance a borrowers home and add home improvement funds. At the closing, they decided not to improve reducing amount. Must we issue a new PTIL?
Does the SAFE Act require us to conduct an annual audit? And if so, what is the Section of the Act that supports this? What does it say?
I have received a call from a compliance sales group that says the first $100 of the held amount changes effective 7/21/2011 to $200.00 I cannot find this regulation change. Does anyone know about this? If so where can I find the change in the regulation.
There still seems to be some confusion over whether the Regulation CC change from $100 to $200 availability is required by July 21 or whether it has been postponed until the CFPB issues regulations. Do we need to comply by that date?
Has the $100 availability amount regarding Reg CC changed to $200 or is it still $100? Is this maybe a change that was included in all the Frank-Dodd Reform Act stuff? If the $100 availability amount did change to $200, when was the change effective? Was it an immediate change?
During one of our recent exams, it was suggested by the examiners that we open accounts online (which surprised us); they would like us to phase out our brokered deposits and felt we could replace these deposits by opening accounts online. I have been trying to gather some information on what is involved in opening accounts online, in particular the risks involved; how to handle CIP, how to handle disclosures and how to obtain the initial deposit. I put out a question on Banker Threads, but did not receive much information. Can you direct me to any information that would help?Also, our president would like me to do a comparison to Free Checking - the pros and cons vs online accounts. While I have not experienced opening accounts online, I have been at a bank (some years ago) that offered free checking and we had a good experience. Few losses, customers really liked not having to worry about a maintenance fee, and the average balance tended to be around $3,000. I was wondering if you could direct me to any other sources that might be able to provide information or statistics on free checking?
Is there a FRB, UCC regulation or law that requires a minimum number of days that a check can be limited to before being considered void?
We are a State Bank. Do our loan officers and assistants need to be registered in Texas? I'm getting conflicting information from different sources.
I am wondering if there are any specific regulations or guidelines pertaining to mobile banking. We are going to add a function onto our internet banking website that allows customers to choose an option to access their account(s) from their mobile devices. I would just like to know if we need to consider other compliance issues separate from internet banking.
With the Fed clarifying that balloon mortgages under seven years are still allowed, as long as the lender uses prudent underwriting, this still does not give back the presumption of compliance protection, correct? An individual borrower could bring suit against the lender for harm, right? In order to regain the presumption of compliance protection, would a bank need to offer a seven year plus balloon term?