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Chat! - BOL Watercooler
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Papa was a Rolling Stone - The Temptations
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Flood Compliance
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No.
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BSA/AML/CIP/OFAC Forum
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Understood. I didn't think about that. This document does not contain any copyright or identifying detail.
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BSA/AML/CIP/OFAC Forum
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I'll add to the thread with an example. We had a downtown C-store owner start withdrawing larger than normal amounts of cash weekly. We couldn't figure it out and thought it was suspicious and reportable. The number of reasons we could imagine was greater than the threads would allow. In the end we asked. Guess what, she wrote a bad check to a supplier and was put on a cash only basis for 6 months. Being her bank we could verify the check issue was true.
I'm not saying that's the case here, but the point is, you don't know. You need to decide if it's abnormal enough. Randy's point is also very valid as he said above, it's likely this relationship is costing the bank money to operate. Add the risk to that you have for criticism over the transactions and you should have a good explanation or have taken action. Remember the "S" is not for guilty and what if when filed law enforcement puts your SAR and CTRs with any number of others on the same fellow? Conversely, what if they can't? Either way you're covered on the risk side, but still need to address the negative income account.
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BSA/AML/CIP/OFAC Forum
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I do not know if this helps. If it is a rush request, I ask the person to send me an email with the agency name in the address.
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Lending Compliance
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Have you been re-issuing CDs if they have already be issued and signed? What about rescission on loans that closed yesterday or this morning?
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BSA/AML/CIP/OFAC Forum
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I appreciate your help. Thank you!
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General Discussion
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Should a bank still maintain a "Do Not Call" or TCPA policy?
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HMDA
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If it is all the same bank - you have a real problem with that statement. You cannot deny an applicant because they gave the application to the wrong department.
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Deposits and Payments
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I have seen this written up in the past as not clearly disclosed.
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TRID - TILA/RESPA Integrated Disclosures Rule
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Our investors stated they would not take a loan from us with the incorrect disbursement date, even going back to the 15th closings. As Randy stated, we will have to issue revised RofR and CDs on some loans.
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Need to Remain Anonymous
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When you are looking at "underserved" tracts, you also need to look at the housing availability. We've seen in some MMT where the rental housing exceeds the owner occupied housing. There are expectations that OO housing will be bought and sold as people move, and have potential for refinances and home improvements. Rental housing however is an investment, and usually not something financed.
As an example, for 13 MM tracts in 2 Florida counties: (rounded)
Total Housing 25,900
Occupied 21,400
Vacant 4,800
Owner Occupied 10,100
Renter Occupied 11,400 (44% of the housing in the tracts)
Out of the 25,900 units, there is minimal possibility for lending in 11,400, therefore cutting down almost in half the potential for lending.
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HMDA Overhaul 2018
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Ah, now I get it. Thanks Dan, that's the help I needed!
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General Discussion
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We had an investor 30 mins ago send an email out that Saturday would not count in our "days" count. What in the world? That affects purchases who had CDs sent out yesterday to close Monday, and of course as mentioned any refis that closed late t his week. :|
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Marketing
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I talked to our marketing department and they are wanting to keep the wording like it is so I am looking at the disclosures that are needed since there is a triggering term. Would I need to give two payment examples, one for the 9 Month Construction Fixed Rate and one for the 12 Month Construction Adjustable Rate?
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Audit
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Hello,
New to this forum. We're struggling to figure out how to apply q-factors for CECL and was wondering if anyone can give some input on how they are applying q-factors/approach used for CECL?
Thank you.
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BSA/AML/CIP/OFAC Forum
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State law and if they need to be treated as a partnership under IRS tax rules are two different things. Not sure what a FBNS statement is.
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New York
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That is the selling guide. I thought you were asking about termination. Maybe I misread your question since you were talking about HOPA.
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Marketing
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Posting factual information is not advertising, but I think you need to pay attention to: Copyright 2020 Mortgage Bankers Association. All rights reserved.
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Chat! - BOL Watercooler
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Frank Bonner, 'Herb' of WKRP, at 79
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TRID - TILA/RESPA Integrated Disclosures Rule
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Like I said - then find a new title company and report them to your State Department of Insurance as in every State that I can think of, this would be an illegal practice.
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Deposits and Payments
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Am I reading it correctly that since the Fed is still processing three is no impact to funds availabliity this year?
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CRA
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Sure, a quick way to accomplish this is to increase a diversity supplier program goal for minority and women owned businesses. Big banks have already issued ESG bonds.
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Flood Compliance
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1. Each building must be insured.
2. No building can be insured for more than its' insurable value.
3. The maximum is $250k on residence.
Apply these 3 rules to your scenario until you reach the "lesser of 3" requirement.
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Flood Compliance
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In order to apply the detached structure exemption, the detached structure must be used primarily for personal, family or household purposes. Even if this "transitory residence" is considered residential, is the building in the floodplain going to qualify? It sounds like this property is used for non-consumer purposes.
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