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Operations Compliance
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Never mind...found what I was looking for... Assume an institution does not provide an opt-in notice, but authorizes an ATM or one-time debit card transaction on the reasonable belief that the consumer has sufficient funds in the account to cover th
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Lending Compliance
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Federal Reserve
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Chat! - BOL Watercooler
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Alone in the Dark - Testament
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S.A.F.E. Act Forum
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So we're ok not having the Institutions Unique Identifier on anything it look like! Thanks!
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Indiana
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I ran across this property tax estimator while looking for something else. Thought I would share it as a FYI. https://gateway.ifionline.org/CalculatorsDLGF/TaxCalculator.aspx
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Need to Remain Anonymous
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Overdraw account #1 and then review your account agreement and applicable state law to determine if you have right of setoff against account #2. "Only signer" does not tell me the ownership of each account. For example, if I have two corpor
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CRA
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My understanding is that you no longer need it in your lobby. But the CRA requirement is that small banks must include loan-to-deposit ratios for each quarter of the prior calendar year and large banks include the CRA disclosure statement from the FF
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BSA/AML/CIP/OFAC Forum
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Originally Posted By John BurnettIt's a lot harder for a customer to ignore a teller's question than a letter with that same question. The letters will get tossed by most customers. Agreed, but now I'm curious... how do you train tellers to press
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BSA/AML/CIP/OFAC Forum
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Can someone "dumb" this down for me? I think my bank is maybe "working harder" not smarter. Do you all check domestic and International ACH? From the FFIEC- OFAC Screening ACH transactions may involve persons or parties that
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Deposits and Payments
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Customer requests remittance transfer "to them from them" to a Beneficiary Bank in India. Customer disputes the transfer correctly within 180 days, alleging funds not received. 90 day investigation period begins. Intermediary bank contacts
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Flood Compliance
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At some point - yes - like as soon as you suspected they were no longer able to make their payments and you modified the loan.
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Chat! - BOL Watercooler
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MB Guy: Their Rock & Gem camp is great, both of my girls went to it every summer until they aged out.
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TRID - TILA/RESPA Integrated Disclosures Rule
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Agreed. This is just another one of those conundrum situations we hear about in the news.
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The BOL Couch
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agreed with the lateness! and Peepers thanks for the laugh, I laughed out loud and got some looks... I hope I am not someone's pet peeve!
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Flood Compliance
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Do we need to have any non-NFIP policy that we have accepted and are currently in place reviewed for the private insurance requirements as of 7/1, or would we just need to tackle them as they come up for renewal?
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Need to Remain Anonymous
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but if the LO is getting the referral and the free advertising there is no exchange Would you care to explain this statement? I'm not sure how the MLO receiving free advertising is not an "exchange" of something of value. The Reg. states
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Lending Compliance
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We are looking to introduce a pre-approval program and I would be interested to see how other banks are handling this. Would anybody be willing to share their policy / procedure on a formal pre-approval program?
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Lending Compliance
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I have always been of the opinion that 17(c) would prevent the bank from charging anything extra in the escrow account other than the anticipated disbursements and the allowable cushion. Maybe it would be acceptable if the fees were outside of the es
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BSA/AML/CIP/OFAC Forum
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You need to maintain records of the purpose of these loans, but tracking the disbursements... you'll need to ask your auditor. Here's what you do need a record of (https://www.ffiec.gov/bsa_aml_infobase/pages_manual/OLM_116.htm): "Extension o
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S.A.F.E. Act Forum
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We hired a remote employee who lives in another state where we do not have a physical business office. What address should I direct him to use to complete the Employer Work Location part of the MU4R?
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General Discussion
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rlcarey's link, which essentially states that an application for a modification is an application under Reg B, points to a FRB Letter (https://www.federalreserve.gov/boarddocs/caletters/2009/0913/caltr0913.htm) that states that for modification reque
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General Discussion
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rlcarey, thank you for your response. I too do not understand why people go this route but thankfully, my lenders are good in ensuring that disclosures are needed before proceeding. I will let me underwriting department know on pricing. Thank you
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Need to Remain Anonymous
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Thank you so much
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Deposits and Payments
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John, when you say "if there have been recent returns of checks on that outside account"....what is a good rule of thumb for "recent" I'm reviewing an account that had chargebacks back in March-Aug of last year......customer has
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Operations Compliance
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That sounds pretty reasonable to me. "Reasonable" is not defined in the regulation.
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