Have the October 2019 proposed changes for the Community Bank Leverage Ratio (CBLR) Framework been finalized?
I understand that you must report the FCRA info on adverse actions if you used information from a credit report to deny the loan, but does this include using the debt listed on the credit report as well? We did not deny based on the credit score (over 700) but did deny due to excessive obligations in relation to income.
We have a “spin the wheel” promotion. To spin, a customer must donate $1 that the bank donates to a charity. All the prize amounts on the wheel are more than $1 therefore all customers will get more than they donate. The amount won is then sent to the customer via our e-wallet app. We set a certain number of spins and it is done on a first-come-first-served basis.
Construction loans can be difficult. Does the proposal address these?
If an EFT claim is made long after the statement is sent showing the transaction, the rules of investigation don't apply. So why do we investigate any of these claims?