Latest Compliance - Reg. B Topics

Small Business Loan NPRM Immanent

09/05/2021

Is use of a general AAN turndown reason such as: “Unqualified co-applicant” considered specific enough for Reg. B compliance or should a general turndown reason like this be avoided?

Covered loans and the DMDC database

08/22/2021

Does the DMDC database include dependents of a covered member?

Court approval for voluntary SCRA repo?

08/22/2021

Does vehicle voluntary surrender apply in conventional close-end loans?

What is “fair servicing”?

08/15/2021

What is fair servicing?

Rule on Tolerance After Closing of Loan

07/18/2021

What is the rule on tolerance of what the lender is allowed to change on loan documents after the closing of the loan?

Withdrawn Loan Request vs. Denial of Request

03/08/2020

Please define differences between a withdrawn loan request by the customer and a denial of a loan request by the bank.

Notice of Right to Receive a Copy of an Appraisal

03/03/2019

I have questions that bother me when I dealing with a commercial real estate transaction where a residential property is taken as collateral. When does the Notice of Right to Receive a copy of an Appraisal apply? I have seen many different concepts in the internet regarding to dwelling: - A 1-4 residential property which is the borrower or guarantor's principal residence; - Any 1-4 residential property which is the borrower's principal residence, and it is going to be refinanced; or - Any 1-4 residential property taken as collateral in the commercial real estate transaction. I would like somebody clarify which is in compliance. I am in Florida if that matters.

Violations w/Regs B&C and UDAAP? Denial Reasons

02/03/2019

Are there possible compliance violations with Regulations B & C and UDAAP if denial reasons are different on the HMDA LAR than what was on the Notice of Adverse Action? For example: at the time of decline, the denial reason listed on the NOAA was "Other", but when the file was reviewed for HMDA data validation, the true denial reason should've been a Collateral decline.

Collection of Demographic Info for Interview

01/06/2019

This question is in regards to collection of demographic information in a face-to-face interview. The applicant checked Mexican under the Ethnicity section but did not check Hispanic or Latino. The loan officer checked Hispanic or Latino and answered "Yes" to "Was the ethnicity of the borrower collected on the basis of visual observation or surname?" Now we are getting validity exception V629. Should the loan officer have checked "No" to the information was collected based on visual/surname?

List of Services in Lobby-Omit Disclosures?

12/02/2018

Marketing has created a list of services that the bank offers (checking, savings, loans, investments, etc.) in a creative design. The window cling will only be visible inside the bank. The bank name, member FDIC, Equal Housing Lender and Not, Not, May are not included on the window cling. Can we omit these disclosures since it is in the lobby and the list is generic?