There is a checking account that has not been used for over a year and has a very small balance. Attached to the account is a Debit Card that has been EXPIRED for over a year. The debit card has/had an annual fee associated with it. The customer never received, used, ordered or requested a replacement card once the old one expired. The bank recently charged the annual card fee to the account which overdrew the account. The bank then began to charge daily overdrawn account fees and now is threatening to report the customer to various agency unless they pay the nearly $80 in fees. Are the fees justified?
Can you run the name of an authorized signed on a business account through ChexSystems without obtaining approval? Or is the fact that he/she signed the signature card for the business account sufficient authorization?
What does the 60 day time frame apply to? Do you start counting back from the last transaction 60 days if the rule applies?
I need clarification on what constitutes a multi-family dwelling for HMDA purposes. I have a loan that has 5 stand alone townhouses that are listed on one deed. Is this truly a multi-family for HMDA reporting, or does it fall into the 1-4 family category?
My question deals with Adverse Action Notices...section # 5 the disclosure of use of information obtained from an outside source. I fully understand the first block for denials based on a credit report and all the information that now must be included. I am confused at the last box that is saying our decision is based on information obtained from another source other than a credit reporting agency. If we have to decline a client for the condition of their real estate and we received that information through an appraisal report should we be utilizing that box? Again this is when the denial decision was NOT based on any part of a credit report or credit score?
If a customer cashes a cashiers check for $20,000.00 and deposits $2,000.00 of that into their own account, do we file a CTR for 18,000? Or would it have been for 20,000?
When two people are the mortgagor, what is the reporting requirement for the 1098? Are you supposed to issue 1 or 2 1098's?
Under Reg GG, how does Internal Audit go about setting up a review that will satisfy the regulators?
Are we required to disburse a loan on the 4th day of the Rescission period? We have some lenders believing they can disburse the loan any time after the 4th day. As a result, I have run into problems such as when to date the loan on the system and what action taken date to use for HMDA reporting.
We have a customer who has been in Afghanistan for the past 5 years due to their being in the military. The customer has come back to the United States and has discovered unauthorized withdrawals which took place 5 years ago - about a month after they were deployed. Are we in compliance if we deny the claim, or we obligated to pay due to fact our customer was not receiving statements to Afghanistan. The account was charged off in 2007 and customer discovered this on her credit report.