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?
FACTA Negative Information Notice
10/20/2008
We are currently providing a FACT Act negative information notice to our second mortgage applicants. This notice also includes the member's current credit score and the corresponding CRA. Are we required to provide this notice to our consumer loan applicants as well?
Reg D Transfer Limitations & Return Items
10/20/2008
Under the Reg D limitations, if third party checks or ACHs are posted to the customer’s account then returned next day with an effective dated entry does this count towards the transaction limits? Our institution is a pay bank. Items post to the account then the pay/return decision is made next day. Items returned are effective dated for date of payment.
Reg B & Senior Citizens Account
10/20/2008
Is it a violation of Reg B to offer a senior citizens account?