Most Popular Compliance Content
HMDA & the Unlivable Mobile Home
10/20/2008
A person gets a loan to purchase a piece of property that contains a mobile home, but the mobile home is not livable and will be sold off so the loan purpose is to purchase the lot only. However, in addition to the purchase money, the customer's loan for the property which contains his residence (a mobile home) is rolled into the new loan. Is this considered a refinance for HMDA purposes?
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?
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?