10/04/2020
Is there a matrix that shows training requirements for the different regulations? I know BSA is an annual event, but I'm looking for guidance on Reg O, Fair Lending, UDAAP, etc. and especially for the board of directors.
05/24/2020
Is a large bank required to send adverse action notices when a payment due date change or extension is denied for consumer loan products?
05/03/2020
What is required in our notice to customers regarding the change to Reg CC?
03/08/2020
Please define differences between a withdrawn loan request by the customer and a denial of a loan request by the bank.
01/26/2020
This question has come up before but I have not seen a clear answer. If the application is NOT taken face to face, how should the collection method questions be answered for HMDA? Code 3 (NA) is only supposed to be for applications where the requirement to report the data does not apply to the covered loan. We would use code 3 on applications where it is an entity. Code 2 (not based on visual observation) would be the only choice that would make sense. What are your thoughts?
01/12/2020
Can a financial institution offer a current customer a gift card if they participate in an online survey that is sent to their email that we have on file? We are not soliciting a product, just wanting their opinion on our services.
01/05/2020
There is a surplus in the borrower's escrow account, but the loan is past due. Can we apply this surplus to his loan? The surplus is $315.44 due to decrease in his homeowner's insurance premium.
12/22/2019
On an ag/commercial loan, if there are two borrowers, do both need to sign an extension agreement or can just one of them sign and extend a loan?
12/01/2019
We are advertising a $125 bonus that will be paid when a customer completes a few requirements, including opening 1 of 3 various non-interest and interest-bearing checking accounts, signing up for a direct deposit, and using our mobile banking app. I wasn't planning to disclose an interest rate or APY to avoid the additional disclosures caused by the trigger term. However, when disclosing a bonus, the APY appears to be a requirement. I wanted to verify that we have to disclose the APY (using the term annual percentage yield) and the additional disclosures caused by this trigger term if we are disclosing a bonus. Or, does the APY disclosure requirement for a bonus not apply if we were not planning to disclose the interest rate or APY? Also, are we required to use the word "bonus" in our ad?
11/24/2019
For HMDA reporting purposes: An applicant's demographic information is obtained at time of application via an online application process and the data collected is the information input onto the HMDA LAR. But if the applicant changes the demographic info at consummation (at the title company) do we change the data on the LAR from the data collected at application to the data collected at consummation?
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