At your recent seminar in NJ you stated that we can not photocopy a customer's picture id before we open a savings/checking account. Which reg does this violate, please cite the section.
Can our bank use a very recent flood determination from another lender? Periodically we will have simultaneous closings with us and a mortgage company and we want to save the customer the added expense of another flood determination.
Can you direct me to current articles on e-statements (security and disclosure)?
I understand that effective 4/24/02 each financial institution has to establish an Anti-Money Laundering program.Isn't the BSA Policy the same or does it have to be a separate Policy?
If a customer applies for a loan secured by residential property and we give them a good faith estimate and they come in a few days later requesting a loan for a larger amount, do we need to give them a revised good faith based on the larger amount?
First, it is important to remember that there are two types of information sharing that will be authorized under the Patriot Act.
A former bank customer recently opened a business account with us. When this nonlisted business originally banked with us several years ago, it was designated as an exempt person with respect to the currency transaction reporting requirements. They've asked to receive the same designation as before. However, the regs state that a nonlisted business must maintain a transaction account at the bank for at least 12 consecutive months before filing for an exemption. In light of the fact that this business formerly had an account with the bank,and was designated as exempt, can the 12 month requirement be waived in this case? The customer is very vocal about this and has been pressuring our frontline personnel for an answer.
I'm a new compliance officer and I need to know what regulations require employee training. I'm in the process of putting together a compliance training calendar for my bank.
We have a situation with the HUD1. In our last examination we were told to identify to whom all fees are paid on the HUD1. We are dealing with secondary markets. One of the mortgage companies is claiming that they are being fined by the brokers because the commitment fee is identified as being paid to them (which it is) and not our bank. They claim that because we collect the fee which they receive, not us, that we must identify that fee as being paid to us. I also cannot find in the regs where it states that to whom all fees are paid must be stated. I can find where it states that they must be itemized. Can you help me with this?
Are there any online banking courses that you reccomend? I am looking for a site the offers Rules and Regs training as well as soft skills. I would like to roll this online training out to all of our branches in Texas.