11/16/2009
I found while auditing a file, that a mortgage loan was disclosed as a 30 year product but the note and loan closed as a 5/1 ARM. I'm trying to determine my next course of action regarding this matter. Do I need to redisclose and book the loan as a 30 year fixed even though the note is a 5/1 ARM?
11/16/2009
Our bank is second in a participation loan. Do we have to obtain identification and CIPs for the guarantors?
10/19/2009
Recently a seminar was held by Jack Holzknecht on the new Reg Z requirements that began 7/30/09. One of his points on the timing of early disclosures was that the delivery rule was satisfied upon putting the disclosure in the mail. We attended a FED "Call the FED" phone seminar last week and the regulators stated that upon mailing of the disclosure you must wait three days before starting the seven day waiting period before loan consummation. Who is correct?
08/17/2009
Do tellers need to run an OFAC check on a non-customer that comes in to cash a check on a customer’s account? The checks range anywhere from $5.00 to over $2500.00.
08/10/2009
Do you know if the FDIC can retroactively assess flood penalties for loans that had a flood deficiency and have subsequently paid off, or a loan for which a deficiency was discovered and remedied by the institution but was outside the 45 day window?
07/13/2009
Regarding Reg CC Compliance and differentiating between banking and business days: I thought a banking day was a day when a branch may offer hours and basic services(i.e., a Saturday), but not all services are available to a customer, whereas a business day is Mon-Fri (excluding holidays) when all services are available. Now I am reading in a tutorial that a banking day must be a business day, so Saturday should never be considered a banking day. What is your answer?
07/06/2009
If a bank were to have a Regulation B violation by requiring the signature of a non-participating spouse as a guarantor in a secured commercial business loan, do they really have that guarantor or would that signature be considered invalid? Would they be able to use that signature to get other documents, such as deeds of trust and or a release of claims from the same nonparticipating spouse, or is that just more violations of Regulation B? What sort of consequences would the bank be facing? Do you know of a Regulation B expert consultant I could speak to or consider hiring?
05/25/2009
How can the bank cut cost in risk and compliance management for third parties?
05/18/2009
How to Implement Risk-Based OFAC Monitoring Practices
Five steps to risk assessment; ten practices for monitoring
by Timothy R. White, CAMS
04/27/2009
How can the bank cut cost in risk and compliance management for third parties?