Most Popular Compliance Content
Reg Z - Vacant Lot Purchase
10/20/2008
Does Reg Z apply to a vacant lot purchase? The applicant is hoping to build on the lot sometime in the future. I understand that RESPA does not apply unless the applicant is looking to build on the unimproved lot within two years.
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?
Oversight of Service Providers
10/17/2008
Our credit cards are issued by a third party. We don't do the underwriting and the accounts are not on our balance sheet; our name is on the card and we receive fee income from the third party. What, if any, is our obligation in relation to oversight of service provider relationships?