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Questions Answered
11/27/2022
Is there a regulation addressing the changing of payment due dates on installment loan? I'm not sure if this is federally regulated, state, or both. Is there a limit on the number of times customer can request, and the length (number of days) it can change?
02/06/2022
What regulation dictates the interest basis for a second mortgage?
12/12/2021
I am searching for a policy for the financing of boat docks/slips. Senior management is at odds with one another over whether it is prudent to require the real estate adjoining the dock or if the asset itself is marketable. One senior manager argues that the permit is the value in the asset? So we are looking for a sample policy on this, and any insights from those familiar with such loans.
10/03/2021
We are a small community bank with $250 million in assets. We have lost our compliance officer again. Unfortunately, we can't justify a full time position for this. Do you know if banks are outsourcing this function and if so, where do I look to find the firms who offer this service?
05/09/2021
Is it a requirement (Reg or Legal) to keep hard copies of Signature Cards with wet signatures?
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?
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.
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.
09/13/2020
Can a relationship manager be personally liable for flood damage?
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?
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