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Chat! - BOL Watercooler
Jump to new posts Re: Song Titles by GuitarDude @ Yesterday at 04:56 AM

Crazy Little Thing Called Love - Queen
Fair Lending
Jump to new posts Re: High Minority Census Tracts by Rocky P @ 03/06/21 06:15 PM

Interagency exam manual

Indicators of potential discriminatory Redlining such as:
R1. *Significant differences, as revealed in HMDA data, in the number of applications received, withdrawn, approved not accepted, and closed for incompleteness or loans originated in those areas in the institution's market that have relatively high concentrations of minority group residents compared with areas with relatively low concentrations of minority residents.

FRB considers Blacks and Hispanics disadvantaged.
Deposits and Payments
Jump to new posts Re: Playstation Dispute by rlcarey @ 03/06/21 12:22 AM

If he previously authorized recurring charges through the PlayStation account to be charge to his debt card, his claim is with PlayStation and not the bank,
Lending Compliance
Jump to new posts Re: mortgage reactivation procedure by rlcarey @ 03/05/21 11:40 PM

You are sort of in no-man's land - I would be going with the original LE from a tolerance standpoint since this was your screw up.
TRID - TILA/RESPA Integrated Disclosures Rule
Jump to new posts Re: Title Company Document Prep Fee by rlcarey @ 03/05/21 09:42 PM

Well, then you have to weigh that against excluding it under:

1026.4(c)(7) Real-estate related fees. The following fees in a transaction secured by real property or in a residential mortgage transaction, if the fees are bona fide and reasonable in amount:

(ii) Fees for preparing loan-related documents, such as deeds, mortgages, and reconveyance or settlement documents.

or the basic uniform charge for a cash or credit transaction:

4(a) Definition
1. Charges in comparable cash transactions. Charges imposed uniformly in cash and credit transactions are not finance charges. In determining whether an item is a finance charge, the creditor should compare the credit transaction in question with a similar cash transaction. A creditor financing the sale of property or services may compare charges with those payable in a similar cash transaction by the seller of the property or service.
Newbie Nook
Jump to new posts Re: Rescission by raitchjay @ 03/05/21 08:54 PM

So why does he want a (i'm throwing out theoretical numbers) $40,000 loan where $35,000 will pay off the existing loan and $5000 he will use to pay DOWN this new loan to an amount of.......$35,000. What's the point of that?
BSA/AML/CIP/OFAC Forum
Jump to new posts Re: Two Financial Institutions on a SAR??? by Compliance Slave @ 03/05/21 08:48 PM

I have the same question.
Deposits and Payments
Jump to new posts Re: SSN for Resident Alien Children by Bankwoman1 @ 03/05/21 08:33 PM

They have not presented green cards but I'm also not sure the account rep asked. I talked to the account rep just now and all they have provided us for the children are the SS cards that say for work purposes only and birth certificates from the country they were born in. I have asked the account rep to ask the father if they have green cards - as I've found that many times when we ask a customer if they are a resident or non-resident - they aren't always correct in what they say. As I don't believe they fully understand the way things work. (who does??) I went ahead and instructed her to find this information out and if they have a green card then I told her to ask them to get their SS cards updated. I'm in full agreement that the children's cards would not say "for work purposes only" at their ages.
Deposits and Payments
Jump to new posts Re: Reg E by rlcarey @ 03/05/21 08:30 PM

Is not when they report it, it is when the transaction happened.
Deposits and Payments
Jump to new posts Re: Credit card dispute question by madukes @ 03/05/21 06:55 PM

Capital One LOL, they even looked up to verify that I received the refund and that the credit from the beginning of December was still posted and they are both still posted.

thank you!
General Discussion
Jump to new posts Re: Recurring Transfer & Death of Account Holder by rlcarey @ 03/05/21 06:06 PM

Until you are officially notified of the death, I would let sleeping dogs lie. Once you are notified, then the amount of funds in the savings account on the date of death would be released to the POD and the additional monies could then be placed back into the checking account for the executor to deal with.
TRID - TILA/RESPA Integrated Disclosures Rule
Jump to new posts Re: Modifying Construction Loans by rlcarey @ 03/05/21 06:03 PM

It would all depend on whether what you are doing would be considered a refinance under 1026.20(a).
Deposits and Payments
Jump to new posts Re: Reg E Provisional Credit reversed. by BrianC @ 03/05/21 05:51 PM

If you can resolve the claim by confirming your suspicions prior to the 10th business day, then no provisional credit is required because you deny the claim. However, if your investigation is ongoing, there are no provisions in Reg E for withholding provisional credit other than if the customer fails to provide written confirmation or at most withholding $50 in the event the claim involves an unauthorized EFT using an access device.
eBanking / Technology
Jump to new posts Re: Online Account Opening Emails by Andy_Z @ 03/05/21 05:24 PM

Actual case on point for this. "Back in the day" not all banks had websites or internet banking. To market internet banking they showed screenshots of the program using dummy account info. These screenshots did not show "Member FDIC" because the program doesn't have that on the pages - these were (simulated) existing customers with existing account information. The problem was, when you use that screenshot to sell the product with new accounts, it is an ad and the disclosure was required.

As Richard noted, no NDIPs, no downside. And to the OP, it's not a violation to not have it but things sometime get repurposed and that's when each needs to be reviewed, as in my example.
eBanking / Technology
Jump to new posts Re: Texting a customer a message by Andy_Z @ 03/05/21 05:11 PM

It is transaction specific. The problem I see is if I received this without expecting it, I'm not using any links and I'm not calling a number I don't know. In the last few days I received text messages saying "Your information was compromised! Do you recognize the following transaction..." and there is a cryptic link. I also came in 3rd in an Amazon Apple Earpods giveaway and there was another cryptic link to claim my prize. My son (why I got the text I have idea but it used his name, won an Apple iPad, he was 1 of 10 winners, yippeee.

My point is, have them call the bank's main number and ask for a person or extension, not a direct number. Transparency is safer even when it includes multiple steps.
BSA/AML/CIP/OFAC Forum
Jump to new posts Re: Bank Risk Assessment - Geographic Areas by P*Q @ 03/05/21 05:10 PM

Everyone one of our locations is in a HITDA area, so all customers are.
eBanking / Technology
Jump to new posts Re: Non-Reg E Dispute by Andy_Z @ 03/05/21 04:19 PM

Internally, working off the applicable chargeback timelines I believe it behooves a bank to procedurally set internal timelines so that nothing falls through the cracks. Like consumer accounts, these should be tracked for progress and have internal controls with deadlines for completion. Business accounts may simply be longer or allow more flexibility.
Lending Compliance
Jump to new posts Re: I/O Mortgage to Affluent Customers Only by Tarhe @ 03/05/21 04:16 PM

Thank you!!
BSA/AML/CIP/OFAC Forum
Jump to new posts Re: Renewing CTR Exemption by Richard Insley @ 03/05/21 04:04 PM

Originally Posted by John Burnett
if you want to make them exempt again.
OP - Don't dismiss this option out of hand. Sometimes it's simpler and cheaper to file the occasional cookie cutter CTR and forget about the option to create a Phase 2 exemption.
Lending to Servicemembers (SCRA, JWNDAA), War, Terrorism
Jump to new posts Re: HUD SCRA Notice Expiration by rlcarey @ 03/05/21 04:01 PM

Not yet - they are historically late. Sometimes years.
TRID - TILA/RESPA Integrated Disclosures Rule
Jump to new posts Re: Agreement with Service Provider by rlcarey @ 03/05/21 03:34 PM

I do not see why not - what is your specific concern?
Chat! - BOL Watercooler
Jump to new posts Re: Things Look Different Today by GuitarDude @ 03/05/21 08:24 AM

Originally Posted by P*Q
Same here, the threads that have a new post have a waffle like looking thing to the left of the topic, thought it was just me too!

mmmm... waffles - Homer Simpson smile
Need to Remain Anonymous
Thank you BrianC. You are always so helpful. :-)
Lending Compliance
Jump to new posts Re: Updated Applications by rlcarey @ 03/04/21 09:58 PM

On run of the mill consumer loans, I think most banks would just document the file regarding the counteroffer and move on if not sending a formal counteroffer to the consumer and they would not bother with an updated application.
Need to Remain Anonymous
Jump to new posts Re: Reg Z 1026.24 applied to unsecured loans by rlcarey @ 03/04/21 09:39 PM

Welcome to BOL.

Comment 1 refers to Comment 2, but the general clear and conspicuous standards apply to all closed-end credit. There should be no reason to go to any FTC definitions.
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