Most Popular Compliance Content
Disclose Fees Borrower Doesn’t Pay?
04/06/2009
Our bank does not charge the borrower a credit report fee when applying for a loan. Therefore, we do not include the fee on the final HUD or on the Reg Z disclosures. We are being questioned as to why not by our internal auditor. His view is that we must disclose all fees related to the transaction even if the borrower did not pay for it.
Reg Z - Website Disclosures
04/06/2009
Our bank is preparing to provide a blank real estate loan application on our website which the applicant can print off, manually complete and bring into the bank. Do we have to provide a CHARM booklet and loan program disclosure on our website with the blank application?
Reg O - Bank Holding Company Chairman
03/30/2009
Is the chairman of the holding company of the bank subject to the more restrictive lending requirements of executive officers of the bank under Reg O?
Outgoing Wire Transfer - Physical Address Required
03/30/2009
Why is it that most banks that originate outgoing wire transfers require a physical address (no PO boxes) for the beneficiary? Is this a compliance requirement and if so, where is it established? I have looked at Reg J, the UCC, the BSA exam manual and the travel rule without much luck. The latter proved more helpful than the others, but still offered little justification for the requiring of the beneficiary's physical address. In this regard, the rule states that the originating bank is only required to retain "beneficiary information provided by the requestor" which may or may not include an address. Any help in determining how and/or why this no "PO box policy" was derived would be greatly appreciated.
Your Vendors & Red Flags: What you don't know can hurt you
03/30/2009
Are banks obligated to ensure that their suppliers comply with the Red Flags rules?