Most Popular Compliance Content
Reg O - Board Approved Revolving Line of Credit
10/30/2006
An Executive Officer of the bank is granted a Board-approved multiple-advance revolving line of credit on 01-01-06 for a one-year term in the amount of $25,000. On 07-01-06 the personal financial statement of the executive officer dated 07-01-05 is no longer considered current by bank underwriting standards. Are additional loan advances after 07-01-06 on the executive officer’s approved multiple-advance revolving line of credit that are within the $25,000 limit considered a violation of Regulation O 12 CFR 215.5 (d)(3) which indicates that any extension of credit by a member bank to any of its executive officers shall be preceded by the submission of a detailed current financial statement of the executive officer?
Decedent’s Right to Financial Privacy?
10/30/2006
Does a deceased person have the right to financial privacy? If a bank turns over money from a deceased customer's bank account to law enforcement without a warrant can the estate object? Does the estate stand in the shoes of the deceased owner of the account?
Deposit Disclosure Booklet Surprise
10/30/2006
I've recently inherited our Deposit Disclosure booklet. There is a small paragraph at the end of the booklet that discloses to customers that their "checking account may become a master account with two sub-accounts -- a checking sub-account and a savings sub-account." It goes on to say we may transfer funds between the two sub-accounts on the Bank's book only and it doesn't affect their account. Are we required to disclose this to customers and if so, where do most banks disclose it? I can't find it in other bank disclosure booklets.
Credit Denied - Disclose Use of Outside Source
10/30/2006
We have a situation where a customer's loan request is being turned down for "excessive obligations in relation to income" and "unable to make loan on an unsecured basis." A credit report was never pulled. The loan officer made his decision based solely on a list of credit card debt provided to him by the customer. Our question is, do we have to disclose that we used an outside source in making the credit decision?
HELOC Past Due - Offset Business Account
10/30/2006
If a customer has a corporate business account and a personal loan (HELOC) that is past due, can we withdraw funds from the business account to cover the past due amount? The business owner is the only signer on the corporate account.