Record Retention for Signature Cards
05/09/2021
Is it a requirement (Reg or Legal) to keep hard copies of Signature Cards with wet signatures?
Richard Insley
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Questions Answered
Advertising Rate Sheet-"Limited Time Offer"
05/09/2021
We are creating a rate sheet to be used by local Realtors. It will provide the current rates for several types of loan products. Under our in-house loan category, Marketing would like to list "Limited Time Offer" as one of the bullet points. I recommended they provide an expiration date. Marketing wants to show that as follows - "Limited Time Offer. May Expire Without Notice." Since UDAAP is governed by perception of the reader what are your thoughts, I am still leaning toward a hard expiration date. What is required, or commonly done?
Increasing Construction Only Loan-Disclosure
04/18/2021
I have a personal construction only loan that we are increasing. How do I disclose the fees that are associated with the increase? Can the bank charge a processing fee? The rate and maturity date are not changing.
Training Requirements for Different Regulations
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.
Relationship Manager Liable for Flood Damage?
09/13/2020
Can a relationship manager be personally liable for flood damage?
Collecting PMI w/o PMI Insurance Company
03/23/2020
If the bank charges PMI and doesn't have a PMI insurance company that it has to pay can the bank truly collect the PMI? For example, if the bank had loans that didn't sell on the secondary market, and the insurance gets cancelled, can the bank still collect for the PMI?
Business Purpose Loan Changed to Consumer?
03/15/2020
Our collateral consisting of 62 acres of farmland, a residence, a hog barn and a cattle barn appraised for $465,000 in 2017. It is owned by an Amish (full-time farm family) borrower. The land and livestock buildings account for $$395,000 of the overall value. The primary residence comprised $70,000. Our first mortgage loan made in 2017 was a business purpose loan. Now these borrowers want to refinance it to add an additional $80,000 remodel. Is this a still a business purpose loan, or will it be a consumer loan? The total loan balance after the new house addition will be $366,000.
Email Notifications Sent for Abandoned Property?
02/23/2020
Can email notifications be sent for abandoned property? My understanding is that this is subject to what each state may require depending on the address the account holder is located. Some states require a written notice to be mailed. So if we meet E-SIGN requirements would that supersede state requirements? Would CAN-SPAM Act also need to be considered as not being in violation since it talks about "notification of a change in the recipient's standing or status"? I'm thinking this Act is more related for purposes of commercial electronic mail.
Threshold for Regulation Z Coverage (Non-RE Loans)
02/16/2020
Should non-RE loans that exceed the dollar threshold for Regulation Z coverage still be considered consumer loans as far as coding and reporting? We have a difference of opinion. One side believes the Reg Z exemption essentially changes the loan into a commercial loan in every way. The other thinks that the disclosures in the documentation is where the exemption is primarily seen and the loan should be coded and reported exactly like any other loan of its type that is under the threshold. Any clarification would be appreciated.
TILA Disclosures Given to Business Entity (Reg Z)
02/16/2020
If TILA disclosures are provided in a loan to a business entity and the APR is understated - is this a violation of regulation Z although loans to business entities are exempt from the coverage of Regulation Z?
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