Reg O - Individual Lending Limit, what is the definition of the term "readily marketable collateral" in relation to an insider's lending limit (the additional 10% of unimpaired capital and unimpaired surplus)? Is real estate with a valid appraisal considered "readily marketable collateral"?
We currently take copies of picture ID when opening new accounts and place the imaged document on our mainframe. We do not have paper files. The question came up whether there are any Reg B violations since this info is readily available to the lenders. We have been through several OCC exams and nothing has been said but now I wonder if there are any problems having this available. From what I see, it is no different than having a paper file with the ID in it but I wanted someone else's opinion.
What are the bank policies that need board approval and how frequently?
I am unable to convince our bank president that telephone transfers and internet transfers are counted in the six that may occur each month on a savings account. I have downloaded the Reg D chart and the law, but he is still not convinced. Can you tell me where I might find more to show him in a clear manner?
Do we need to keep track of who we provide a copy of the annual financial disclosure statements to? Is there a specific fee to charge for additional copies?
I am the compliance auditor for a national bank, and the bank is wanting to loan money to a political party. What paperwork is required for this loan, and what regulation can I find information about this topic?
Regarding Regulation O Section 215.9, relating to Executive Officer reporting loans from other "Banks." Does this definition of Banks mean only members of the Federal Reserve? We are regulated by OCC and I looked in their Insider Activities handbook, but it only states 215.9 Reports by Executive Officers "Executive officers must provide a written report to the board of directors within 10 days of becoming indebted to any bank if the aggregate amount of the indebtedness exceeds $100,000 (or the greater of 2.5 percent of the bank's capital and surplus or $25,000). The report shall state the lender's name, the date and the amount, security, and purpose for each extension of credit."
OCC is taking steps to increase its service for bank customers. The call center, which currently operates for seven hours a day, will be gradually expanded to a 12 hour per day operation schedule.
E. Matthew Quigley is the OCC's new Director of Community Development.
Failures in lending compliance can cost as much as $14,000,000. That's the amount one lender will have to pay for unfair lending practices and compliance failures.