I have a HMDA question. I have loan that is to purchase an apartment complex, 60 apartments in 5 separate buildings. Do I report this all at once or do I report each building separately?
I have a loan where the purpose is to purchase a residential dwelling. The loan is being secured by three other properties that does not include the property being purchased. Which property do I report on for HMDA?
What is the minimum amount of identifying information that the issuer of the subpoena must supply to the bank in order for the bank to be legally able to release financial information? Is it a matter of bank policy or federal regulation?
Can you provide a list of required officer positions? Are these requirements listed in the regulations or are they simply suggestions? I'm trying to determine which officer positions are mandatory for compliance so I may pass this information on to Executive Management.
Is there any regulation that requires obtaining/retaining a copy of a social security number and drivers license for any and all checks cashed for a non-customer, whether it is an on-us check or a check from a non-customer to an existing bank customer? We do understand the need to pull OFAC on all transactions that involve a non-customer no matter the amount of the check. It is very time consuming to make copies of IDs and the checks. Are examiners going to the extreme? If we check identification, it seems that with the OFAC that should suffice. Are all banks required to do this now?
Can we pull a credit report on a customer without their consent? We have a customer who wants to consolidate some credit card debt. We told her that she needed a co-signer. She gave us her husband's social security number. Can we pull a credit report without his authorization?
Is there a regulation for national banks dealing with the Bank Protection Act? I know Reg H is for state chartered banks.
Is it proper for a bank to reclaim a customer's social security funds that were direct deposited on June 3 if the person died on June 2?
Are we legally required to list the complete account number on any bank mailing (overdraft notices, statements or any correspondence to a customer)? Are we allowed to suspend the first 5 of our 10 digits?
Can an UTMA be opened with a ATIN (Adoption Taxpayer Identification Number) until the Social Security Number is issued? If so, are we required to withhold?