When re-titling a CD from the name of the individual into the name of the individual's revocable living trust, I seem to recall that an early withdrawal penalty does not need to be accessed if the "beneficial ownership" of the CD remains the same. Is this true and if so, what is the citation?
Reg D discusses checks payable to third parties as counting for transaction limitation purposes. To clarify, does a check drawn on a money market that the depositor writes payable to himself or herself and deposits at another financial institution count toward the three?
When a non-transaction account exceeds it's sixth transaction that account is to be reclassified as a transaction account. Does the entire balance on that account then become reservable or just the dollars of the transactions exceeding the sixth transaction? How is the unused portion of the balance calculated for reserve purposes?
We are trying to comply with the FDIC SCANS bulletin # Chiro-04-2001 however we are having difficulty finding clarification as to exactly what is required. The FDIC is citing violations for the lack of disclosure of hazard insurance and taxes on GFEs and HUD-1 in a second lien and/or refinance transactions where adequate coverage is already in place and the bank does not require additional coverage or escrow for these items. The bulletin states that if the bank requires these items to be in place, they must be disclosed on both the GFE and the HUD-1 as paid outside of closing (POC). My first question is does the requirement apply to both hazard insurance and taxes? And secondly how are these items disclosed on the GFE and HUD-1, (i.e., are estimates based on current year totals divided by 12 months acceptable)?
Are there any rules or regulations that state when closing a time deposit early and paying accrued interest, the penalty would be based on the principal alone or on the total of principal and interest combined?