Most Popular Compliance Content
Customer Wants Credit Bureau History Changed
10/27/2008
We have a customer requesting that we change the history reported to his credit bureau from derogatory to good. Is there any regulation that we could provide to the customer to state that we are not obligated to comply with the request?
Responsibility for Notifying Dealers and Brokers
10/24/2008
Are auto dealers and mortgage brokers being notified they are required to have ID Theft Prevention programs in place, or is it up to the financial institution to inform them?
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?
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?