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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?
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.
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.
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.
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?
12/29/2019
How can I validate that the APR I have disclosed is correct during a leap year? I noticed that if I enter the loan date as 02/28/19 and the first due date as 03/28/19, APRwin returns that there is 1 period and 0 odd days which matches what our internal software has calculated. If I enter the loan date as 02/29/20 and the first due date as 03/29/20, it returns 0 periods and 28 odd days. This definitely doesn't match our internal software as it also returns 1 period and 0 odd days for this scenario. I've read online that APRwin has limitations for calculations when the year has 366 days. Should we go with 1 and 0 and is there another tool we can use to confirm this?
12/22/2019
Do you need a new flood determination when you are renewing and increasing the loan amount?
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?
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