Most Popular Compliance Content
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?
Reg Z - Vacant Lot Purchase
10/20/2008
Does Reg Z apply to a vacant lot purchase? The applicant is hoping to build on the lot sometime in the future. I understand that RESPA does not apply unless the applicant is looking to build on the unimproved lot within two years.
Oversight of Service Providers
10/17/2008
Our credit cards are issued by a third party. We don't do the underwriting and the accounts are not on our balance sheet; our name is on the card and we receive fee income from the third party. What, if any, is our obligation in relation to oversight of service provider relationships?