Most Popular Compliance Content
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.
Run an OFAC for Each New Loan?
10/20/2008
How often does an OFAC need to be run? I know our database is automatically scanned, but we are running a new one for each new loan even if they are a current customer. Do we need to do this?
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?