01/01/2002
01/01/2002
Two new governors come in and a seasoned governor retires. This makes for a fairly significant change at the Federal Reserve.
12/03/2001
We currently use an employee's social security number as their teller id number. Is this a privacy issue? Is this a misuse of the SSN?
12/03/2001
DirectPointe provides managed computing services that include remote PC and Network Management services. We are working with a community bank in Utah that is interested in our services, but is concerned with any regulatory issues that may not allow us to have remote access to their network and PCs (since their network is connected to a service bureau, which has confidential information). Can you provide any information/insight into this issue? Can we provide remote services and if so, does our company need to meet certain requirements? Please let me know if you have recommendations.
12/01/2001
I'd suggest that you now have in front of you the two forms we've been talking about - The Currency Transaction Report (CTR, Form # 4789) and the Designation of Exempt Person form (TD F 90-22.53).
11/12/2001
11/05/2001
If you have a flood determination that is 5 yrs. old and renew the loan (on the same property, no new money), a new determination is done 3 days after the renewal are you still covered by the earlier determination?
11/05/2001
This question concerns RESPA. If a loan is secured by 2 14 family residences, one already owned and one purchasing, and is for 12 months interest only to give customer time to sell one of the houses is that covered by RESPA?
11/05/2001
Lucy Griffin explained to our Minnesota Bankers compliance group that we must not keep photo copies of picture IDs in loan files because of a possible Reg B violation. However, we also do this when we open new accounts (it could be helpful in cases of identity theft, or just so staff will recognize new customers). We also do it when we make a credit card cash advance for noncustomers, as we have experience identity theft there. Can we do this in nonloan situations and not run afoul of Reg B or other regs?
11/05/2001
One of my loan officers posed this question; What is the definition of "closing" under Flood? The documents have been signed, but nothing has been recorded or disbursed.