I am the Electronic Banking Specialist for [Bank Name Withheld]. We are having a debate among ourselves and our Legal Department regarding whether or not check imaging is covered by Reg E. One opinion has to do with whether the check image is truncated or not; another has to do with the intent for imaging, whether as a tool for the merchant to recover funds on a returned item, or as a bank tool to pacify clients who want their checks back. I would appreciate any input that you might offer as you have a more industry-wide view available, as well as experience in compliance and Reg E issues.
When a Bank has a Reg O violation, an executive officer habitually overdrawing their account and at times circumventing the OD fees, what reporting requirements apply? I am a CPA and our client is regulated by OTS. I understand they must have it listed and ready when OTS examiners come, but are there other requirements? We will make sure the Board is notified, but we need to know if we have to advise bank to notify OTS right away.
A rescindable loan for $20,000 was made and the ROR notice was provided. This loan is paid down to $10,000 and then the borrower refinances the $10,000 and wants an additional $5,000 for a total of a $15,000 loan. Is a ROR notice required for the $15,000 loan even though it is less than the original $20,000?
Is there a dollar amount connected with HMDA reporting for a multiunit complex, apartments or condos?
If a loan request is to purchase a bed and breakfast which will serve as a business and also primary residence, is it RESPA required?