Most Popular Compliance Content
Reg O Exemptions
05/03/2004
Are home/education loans still exempt from Reg. O?
Letting Customers Know You'll Be Competitive
05/03/2004
We are implementing a new sales program to target all maturing CD customers. Our business development director will be personally calling those customers whose CDs are maturing and will let them know that our bank will be competitive on rates and to come and see us for further details. Rates will not be specifically quoted (unless they ask, at which point the Annual Percentage Yield will be quoted first). Are there any other guidelines that I, as the Compliance Supervisor, should share with the business director prior to his calling our customers? For example, would he be able to say "We can beat any rate you find elsewhere in town," or something similar?
IRS Levy and the SSCRA
05/03/2004
Can a bank proceed with an IRS levy on a military individual who's protected under the Soldier's and Sailor's Civil Relief Act of 1940 and Executive Order No. 12744, 56 Fed. Reg. 2663? Can the IRS levy against these individuals while protected under this Act and Orders?
Effective Dates of Escrow Analysis
05/03/2004
When completing an escrow analysis, our company's internal audit procedure verifies that the effective date of each analysis is within 12 months. Recently, I reviewed the RESPA guidelines and find that I interpret this differently. The guideline indicates that a servicer must provide an escrow analysis within 30 days of the ending computation from the last analysis. If I understand this, would it be correct in stating that if my last analysis was effective January and ran through December, the subsequent analysis must be completed by January 30 the following year? If this is true, do my effective dates of each analysis have any bearing on this compliance guideline?
Statement of Condition Availability
05/03/2004
Is it required that the statement of condition be displayed in the lobby area or can it be available to give to the customer if they ask?