Current CTR Form Expires?
10/06/2003
I thought I found on the Web somewhere that the current CTR will expire at the end of August 2003. Is this really the case or am I just confused by all the reg changes of late?
David A. Dickinson
Bio:
David's banking career began as a field examiner for the FDIC in 1990. He later became a Loan Officer for a small bank. In 1993, he established Banker's Compliance Consulting. Along with his amazingly talented Team, he has written numerous compliance articles for prestigious banking publications and has developed compliance seminars that Banker's Compliance Consulting produces.
He is an expert in compliance regulations. He is also a motivational speaker and innovative educator. His quick wit and sense of humor transforms the usually tiring topic of compliance into an enjoyable educational experience. David is on the faculty of the Center for Financial Training, the American Bankers Association National Compliance Schools and is a frequent speaker at the ABA's Regulatory Compliance Conference. David is also a trainer for hundreds of webinars, is a Certified Regulatory Compliance Manager (CRCM) and has been a BankersOnline Guru for many years. The American Bankers Association honored David with their Distinguished Service Award in 2016.
David and his wife Karen have 3 adult children (none of whom live at home!) & 3 cats (which Dave is allergic to). They live on a lake in Nebraska and when possible, Dave can be found fishing or in the water. David plays the guitar & piano and enjoys singing with Karen. Together they lead worship at their church.
See all Upcoming and On-Demand training presented by David.
He is an expert in compliance regulations. He is also a motivational speaker and innovative educator. His quick wit and sense of humor transforms the usually tiring topic of compliance into an enjoyable educational experience. David is on the faculty of the Center for Financial Training, the American Bankers Association National Compliance Schools and is a frequent speaker at the ABA's Regulatory Compliance Conference. David is also a trainer for hundreds of webinars, is a Certified Regulatory Compliance Manager (CRCM) and has been a BankersOnline Guru for many years. The American Bankers Association honored David with their Distinguished Service Award in 2016.
David and his wife Karen have 3 adult children (none of whom live at home!) & 3 cats (which Dave is allergic to). They live on a lake in Nebraska and when possible, Dave can be found fishing or in the water. David plays the guitar & piano and enjoys singing with Karen. Together they lead worship at their church.
See all Upcoming and On-Demand training presented by David.
Areas of Expertise:
Audit Services
Compliance Audits
Compliance Consulting
Compliance Review
Compliance Seminars
Lending
Lending & Operations Compliance Matrices
Risk Assessment
Organization Health / Culture Consulting & Training
Training the Trainer Materials
Training Videos
Questions Answered
What Can a Minor Have?
09/29/2003
Can a minor (a person under the age of 18) have a checking account,savings account, or ATM card without a custodian? Can they sign on an account in any circumstance?
Signing One Form for All Disclosures
09/29/2003
For the upfront lending disclosures (e.g., Servicing Transfer Disclosure, ARM disclosures, etc.) for which the Bank is required to keep a customersigned acknowledgement of receipt, can the Bank substitute a "Disclosure Acknowledgement" form which the customer signs acknowledging receipt of all the disclosures? Or do the regulations require that the disclosures be individually signed?
Reg CC Large Item Exception Hold
09/29/2003
My question is in reference to Reg CC. When handling a large item exception hold, my institution has implemented the policy of making the first $5,000.00 available on the following business day. I have recently read information that leads me to believe that the first $5,000.00 is susceptible to the normal availability schedule. For example, if a $10,000.00 nonlocal check is deposited, I may place an elevenday hold on $5,000.00 and a fiveday hold on $4,900.00 (assuming it is not a new customer). Is this correct?
Guarantor's Right to a Copy of Note
09/29/2003
Must we give a copy of a note to a guarantor of the note? Is there a legal requirement?
HOEPA Disclosures & Closedend Home Equity Loans
09/22/2003
Is the HOEPA disclosure necessary for each and every closedend home equity loan or only the loans that meet the outlined criteria? Perhaps a better question would be this: do specific outlined criteria exist such that all the types of nonHELOC loans would ultimately fall under HOEPA?
Doc Prep Charges on the HUD1
09/22/2003
Our Compliance Officer questions the placement of two items on the HUD1A and the GFE. Should the doc prep charge be placed in the section 800, items payable in connection with the Loan or under title charges, Item 1105. Our title Co states the difference is who prepares the docs. If the bank, it goes in 800 section, if an attorney or title co in title charges 1105. When placed in our doc software in 800 section it does not pass down to same line on GFE and HUD1A. Can you clarify the correct placement of the doc preparation charge?
Savings Account Statement Frequency & Account Activity
09/15/2003
A customer has a Savings account that is set to receive an annual statement. The customer signs up for the Bank's Internet Banking product that allows transfers between the customer's savings and checking account. Question: If a transfer never occurs between the savings and checking account, does the bank have to send a quarterly statement or can the bank continue to send an annual statement?
Home Improvements, New Improvements, and HMDA Reporting
09/15/2003
Client is requesting a $13,000 home improvement loan paying off an unsecured $3,000 home improvement loan with additional funds of $10,000 for new improvements. This is not reportable in 2004 as a refinance. Should it be reported as a home improvement loan or not reported under HMDA at all.
What is HOEPA?
09/15/2003
What is HOEPA?
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