If a customer pays the appraisal fee prior to closing should that fee disclosed as a POC and does it affect TIL?
Are adverse action letters required when a customer cancels or closes a pending or approved consumer loan?
I have recently moved into the compliance area at our bank. The previous compliance officer revoked CTR reporting exemptions for sole proprietorships. Is there anything in the regulations that prohibits us from granting an exemption from CTR reporting requirements to a sole proprietor?
I have two loans, one revolving line of credit with a one year maturity and one term/balloon with a twenty year term. The real estate for both loans is being cross collateralized. Don't we need a separate flood certification/determination for each loan?
We have a Required Service Provider that is a director and this data is properly disclosed on the GFE. Would an Affiliated Business Arrangement Disclosure also be required? My "gut" says yes but the language in our AFBD document tells me no because the AFBD document specifically states "You are NOT required to use the listed provider...".