I am a new compliance officer and in the process of developing a procedure pertaining to ID theft. How do some institutions handle holds on accounts for customers that are a victim of identity theft (FACT ACT)? I know that we could close the deposit account that is affected by the ID theft and reopen a new one, but what about the other deposit accounts the customer has with our institution?
A bank that originates consumer construction loans receives an application from a broker (not exclusive to the bank) as the broker has arranged for the permanent financing. The bank approves the loan for construction that will include purchase of the land/lot. The broker forwarded the application and his early RESPA disclosures to the bank. Is the bank responsible for providing their own RESPA disclosures for the loan they have committed? It seems that the broker's disclosures are only pertinent to his loan.
If a credit report is run during the process of pre-qualifying someone for a mortgage loan does this change the status of an application and require a Notice of Adverse Action if denied?
We are refinancing a residential building that is an Assisted Living Facility and the owners do not live on the property. Is this HMDA reportable? We are thinking just CRA reportable.
Can you point me in the right direction for the section of the Privacy Act that concerns the cessation of bank personnel putting account numbers on the back of checks?