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Operations Compliance
Jump to new posts Re: Ad hoc review of Overdrafts by Likes to Comply @ 15 minutes 16 seconds ago

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
Lending Compliance
Jump to new posts Re: EHL or EHO logo? by Likes to Comply @ 40 minutes 54 seconds ago

Federal Reserve
Chat! - BOL Watercooler
Jump to new posts Re: Song Titles by GuitarDude @ 50 minutes 12 seconds ago

Alone in the Dark - Testament
S.A.F.E. Act Forum
Jump to new posts Re: Unique Identifiers by Parluc @ 51 minutes 11 seconds ago

So we're ok not having the Institutions Unique Identifier on anything it look like! Thanks!
Jump to new posts Property Tax Estimator by Dan Persfull @ 58 minutes 43 seconds ago

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
Need to Remain Anonymous
Jump to new posts Re: Provisonal Credit - Reversal, but..... by BrianC @ Today at 07:59 PM

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
Jump to new posts Re: Annual Disclosure Statement by NoJustNo @ Today at 07:54 PM

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
Jump to new posts Re: Cash Transaction Information by MScarn6942 @ Today at 07:37 PM

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
Jump to new posts How do you check OFAC for IAT? by HLP022010 @ Today at 07:37 PM

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
Deposits and Payments
Jump to new posts Remittance Transfer Dispute Investigation by h1clm04 @ Today at 07:31 PM

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
Flood Compliance
Jump to new posts Re: an a loan be IRED with FPI in place? by rlcarey @ Today at 06:35 PM

At some point - yes - like as soon as you suspected they were no longer able to make their payments and you modified the loan.
Chat! - BOL Watercooler
Jump to new posts Re: Anyone go "gemming" in NC/SC? by Soccer @ Today at 05:58 PM

MB Guy: Their Rock & Gem camp is great, both of my girls went to it every summer until they aged out.
TRID - TILA/RESPA Integrated Disclosures Rule
Jump to new posts Re: Change from "Not Shop" to "Shop" by ccman @ Today at 05:35 PM

Agreed. This is just another one of those conundrum situations we hear about in the news.
The BOL Couch
Jump to new posts Re: Work Pet Peeves by EuphegeniaDoubtfire @ Today at 05:27 PM

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!
Flood Compliance
Jump to new posts Re: New Private Flood Insurance Rules by burke116 @ Today at 05:14 PM

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?
Need to Remain Anonymous
Jump to new posts Re: Flyer in Model Home by Dan Persfull @ Today at 05:14 PM

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
Lending Compliance
Jump to new posts Pre-approval Programs by Lizz Jane @ Today at 05:09 PM

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?
Lending Compliance
Jump to new posts Re: Fee to pay escrowed taxes electronically by StevenD @ Today at 04:26 PM

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
Jump to new posts Re: Loan Disbursement Tracking by Inherent_Risk @ Today at 04:17 PM

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
S.A.F.E. Act Forum
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?
General Discussion
Jump to new posts Re: Forbearance/Deferment Consumer Unsecured Loan by Inherent_Risk @ Today at 03:49 PM

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
General Discussion
Jump to new posts Re: Pricing by Mustang Mama @ Today at 03:43 PM

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
Need to Remain Anonymous
Jump to new posts Re: Loan Estimate Est.Prop Value? by Anonymous @ Today at 03:35 PM

Thank you so much
Deposits and Payments
Jump to new posts Re: Reg. CC - Redeposited Check Hold Reason by Compliance504 @ Today at 03:15 PM

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
Operations Compliance
Jump to new posts Re: EFT Agreement and Signs up for a New Service by rlcarey @ Today at 02:24 PM

That sounds pretty reasonable to me. "Reasonable" is not defined in the regulation.
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