My bank is a small creditor who makes HPMLs. We’ve been claiming the escrow exemption, but now I’m not so sure we should. Sometimes we set up accommodation escrows for extenuating circumstances – does that cause problems?
What is not in the proposal that we need?
I have a question on the new Reg CC update, specifically, on the large check deposit. I have a customer depositing a out of town check made to himself in the amount of $106,000. How do I handle this? Example: 2-12-2020: Place a Large Deposit Exception hold on the check making $200 available 2-13-2020, $4,800 available 2-14-2020 & $101,000 available 2-24-2020. So would the new amounts be $225 available 2-13-2020 and $5,300 (to make a total available $5,525) available 2-24-2020 and the rest available 2-24-2020?
What is the Grace Period for the Community Bank Leverage Ratio (CBLR) Framework?
Our community bank is opening a new branch in a bigger city. Will we lose our “rural and underserved lender” status?