Most Popular Compliance Content
Credit Report - Signature Required on Phone Apps?
03/02/2009
Our mortgage credit applications contain language that allows the bank to pull a credit report. Often that application is received by phone. Is a signature required to pull the credit report and is so, what regulation contains those rules?
Reg E Provisional Credit for Closed Accounts
03/02/2009
Reg E Commentary 205.11(a)-4 requires banks to comply with error resolution procedures for claims on closed accounts. However, Reg E does not provide guidance on how to provide provisional credit in such cases and 205.11(c)(2)(i) indicates crediting customer's account. Our thoughts are to credit another account owned solely by the customer and if no such account exists, to ask the customer for direction on providing provisional credit. If a customer requests a check in the amount of the credit, is a bank required to deliver a check since this provisional credit cannot be reversed as provided by 205.11(d)(2) if the claim is denied?
IRA Exemptions & Reg R Guidelines
03/02/2009
Under the new broker push-out rules Reg R guidelines, it looks like banks do not receive the exemption for IRAs on which they are named as a trustee. Our trust department IRA governing documents name our bank as trustee. It would appear then that we would not meet the requirements of the exemption. Is this the correct interpretation of the IRA and Employee Benefit Accounts exemption language or do we receive the exemption because the accounts are offered/managed in the trust department?
Appraisal Review Fee
03/02/2009
If our institution charges an appraisal review fee and the review appraiser is an employee of the bank, is that charge considered a prepaid finance charge for Reg Z?
Freezing an Unsecured LOC - Notice Required?
03/02/2009
Is a bank required to give notice to consumers when putting a freeze on an unsecured line of credit?