I am filling in for our bank's compliance officers while they are away at training. A co-worker posed the following question/situation and I have been unable to find the answer after some research. Our bank does credit checks/counseling for customers and non-customers. We have a form signed authorizing/permitting us to pull credit reports on the individuals. How long are we required to retain the authorization forms?
We failed to give a timely right of rescission. How can a right to rescission notice violation be cured?
Is there any published reading on banking foreign corporations and how to become familiar with ones such as Mexican, Venezuelan, Bahamian, etc? We want to continue to bank foreign corporations, but want to ensure we are doing what's required by OFAC and Fincen.
I have a question about website record retention. With regards to website changes (disclosures, marketing advertisements, general changes, etc.) is there a concrete retention schedule or best practices for retention? I see many companies treat these changes like a hard copy advertisement change. They will print out the archived page and save it for the examiner. If this is the case, is there a time frame to keep these archived print outs or do you just save them between examinations? I couldn't find any information on the FFIEC website that explains a policy and any website research is very vague.
Where can I find information regarding credit scores? I would like to know more about the factors that affect the score, good and bad, which is better, some balance or no balance, high limit vs. no limit and closing accounts at customer’s request.
Where I can find a good summary of all the regulations which retail banks are required to comply with and the cost related to compliance?
I need to find information regarding each U.S. state's regulations regarding real estate loans. RESPA gives guidelines regarding escrow accounts and fees, but gives each state the ability to overrule the rules if they favor the borrower. What is the best/easiest way to research what rules each state abides by?
HMDA - We have a business loan to three borrowers to purchase a 1-4 family dwelling for investment purposes. One of the borrowers is a formal business entity, and the other two are the two individuals that own the business. The business entity is the primary borrower, but the individuals also sign on the note individually. We are not clear regarding the issue of reporting monitoring information in such a case -- we have had much discussion, and have done much research about this and can't come up with a consensus. In situations where you have a business entity borrowing, AND you also have individuals signing individually on the note, should you report monitoring information on one, or both of the individuals since they are individually signed on the note also? In such a situation would we show the monitoring fields on the applicant, i.e. the business entity as NA, and show monitoring information on one of the individuals under the co-applicant fields? Any guidance you could provide would be greatly appreciated.
By 2010, close to one third of U.S. homes will use only cellular or Internet telephony, according to a recent trends study by Gartner, Inc.
This is a Lending and Compliance issue. We are a State Bank and Member of the Fed. We are in the process of beginning to offer a Automobile Extended Warranty Program. We have cleared the State, and are attempting to work through the Fed. The plan has been approved. However, we are having a disclosure problem. In my research, and information from the Warranty Company indicates that nobody is disclosing the upcharge on the contract as an Additional Finance Charge, which the Fed is indicating we need to do. The upcharge is $200.00 per contract, which really distorts the APR, if you disclose it as an additional finance charge. This is not an insurance product, but the product is insured. Any ideas on where to look and point the Fed to avoid having to disclose this as an additional finance charge?