08/01/2002
FinCEN and the financial regulatory agencies have finally proposed a rule under the USA PATRIOT Act to implement customer identification procedures. This isn't a surprise.
08/01/2002
HUD has published a proposal to make significant changes to the Good Faith Estimate that lenders issue within three days of taking an application. HUD calls this a "simplification" of the GFE.
05/20/2002
Regarding the Right to Rescind on refinance transactions: Is the "Confirmation Certificate" section of the form indicating the borrowers do not wish to rescind required to be signed by the borrowers?
05/20/2002
I know the privacy disclosures must be mailed annually, we mailed last year's in July 2001, do we have all of 2002 to comply?
05/01/2002
With attention focused on privacy, patriotism, and related activities, there has not yet been action on the proposals to amend Regulation B. However, that proposal is very much alive and waiting.
04/01/2002
We are about to mail our annual privacy notices and would like to send a one page letter along with the notice. The purpose of the letter would be a "thank you for doing business with us" and a basic generic marketing message. Is it permissible to include such a piece with the Privacy Notice?
03/11/2002
Do we need to keep mail envelopes for any length of time? These are items sent in by the customer, such as mortgage payments or deposits?
03/04/2002
In looking at possible fees to customers, can we charge a fee for statements that are returned to us via USPS due to incorrect address? If so, is there a dollar or any limitation on the number of times we can fee the customer?
03/04/2002
We were recently infomed from our outside Auditor that with all of the changes in Reg E over the past several years that we needed to do a complete redisclosure to our entire deposit customer base with a separate mailing. We have checked with the state compliance department and they informed us that the only time a Reg E disclosure is required is at the time the account is opened and that a redisclosure is never required. We would appreciate your opinion in this matter.
01/01/2002