Most Popular Compliance Content
Red Flags and Collections Procedures
10/23/2008
When we are collecting delinquent loans, it's common that borrowers will claim verbally that accounts are not theirs, or they never took out the loans in attempts to avoid paying. We already take steps under FACTA to send letters requesting additional information to research these claims, even if the account is legitimate. Is there any other action required under the Red Flags guidelines on these claims that are not legitimate?
Suggestions for New Company for Identifying Red Flags
10/21/2008
What suggestions do you have for a new company (less than one year in operation) that needs to identify the red flags, but has had minimal past experience?
Run an OFAC for Each New Loan?
10/20/2008
How often does an OFAC need to be run? I know our database is automatically scanned, but we are running a new one for each new loan even if they are a current customer. Do we need to do this?
A Separate and Distinct Policy Statement for ID Theft Red Flags
10/20/2008
Are we required to have a separate and distinct policy statement for ID Theft Red Flags, or can it be rolled into our overall FACTA Policy?
HMDA & the Unlivable Mobile Home
10/20/2008
A person gets a loan to purchase a piece of property that contains a mobile home, but the mobile home is not livable and will be sold off so the loan purpose is to purchase the lot only. However, in addition to the purchase money, the customer's loan for the property which contains his residence (a mobile home) is rolled into the new loan. Is this considered a refinance for HMDA purposes?