How long do banks need to retain loan files/ documentation after the loan is paid in full?
Do we have to disclose the actual MAPR to all borrowers?
Can an estate account be opened in a different state from the one the decedent resided in? We have an executor who lives in our state, but the decedent is from a different state. The executor would like to open an account with us after she was told by larger regional banks that they would not open an estate account if the decedent and executor did not live in that same state.
Can we report a past due loan to the credit bureau when SCRA protections apply?
How can banks stay compliant with transactions while not using ACH?
When an incoming wire comes in through a bank or the Fedwire, is our receiving bank required to do an OFAC check? Don't bankers and Fedwire procedures include OFAC checks on them before the wire is sent?
We have an ACH compliance question. One of the credit unions that we audit has reached out regarding an ACH return request. They received the request on 9/1/2022; however, the effective date of the transaction was 7/22/2022. This was returned R06-Returned per ODFI's request and appears to be outside of the requirements for the time of return. The question is:
1) Does the CU have to honor this return and
2) if so, is it acceptable to honor the return via fax? We are thinking that it would need to go through the Federal Reserve?
Does the OCC or other regulatory agencies specifically allow or frown on borrowers taking photos for real estate inspections if the lender requests these through the Verisite Firewall application? The Verisite mobile app can geocode the photos for location confirmation but having the borrower involved may be an issue. Otherwise this could be a way to expedite the processing on some loans.
Am I encouraging a customer to structure if I make them run cash as a deposit into their account ,and then debit their account for a cashiers check instead of letting them just purchase a cashiers check with cash?
I like to have a paper trail and proof that the purchaser is a customer, that is why I run it through an account first.
If we disclose a cost for an Automated Valuation Model/Investment Valuation Model (AVM/IVM) or basic evaluation on the Loan Estimate but the valuation amount comes in low and does not support loan request, if the borrower then requests a full appraisal in hopes of a higher estimated value, are we able to send a new LE with the additional appraisal cost since the borrower requested the full appraisal or does the financial institution need to "eat" the additional appraisal fee because we had already disclosed a lower fee amount?