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12/03/2017
We have a grocery store customer who is an agent for a large money transmitter. The customer offers no other MSB services and is otherwise not considered an MSB other than being an agent of one for this purpose. Is there any prohibition to exempting them from CTR reporting? Is it generally acceptable to exempt these agents from CTRs?
11/26/2017
Once the principal is paid on a charged off loan, is it best practice to collect the interest first or any fees associated with the charge off?
11/05/2017
We have just started with e-statements. Our overdraft protection statements have the same account number as the checking account it is attached to and are created at the same time as checking accounts. Are the Reg E and Z disclosures that we provide with each ODP statement going to be required on every ODP e-statement? Is that also true for the checking statements for Reg E?
11/05/2017
If we deny an application for a consumer installment loan from a consumer who applies with a cosigner, do we need to send an adverse action notice to the cosigner?
10/29/2017
If we are doing a modification for an ARM Loan and the payment increases, some of our staff believe this is a "refinance", some do not. Thoughts? If so, -What do we need to provide to the consumer? There would be no costs associated - just the new terms with the new (current rate)? It doesn't seem like a CD would be appropriate - If not - then we would use our normal modification agreement.
10/22/2017
We have a builder that gives a seller concession on all of their contracts. If the seller concession is more than the buyer needs they do not want us to reduce the seller concession amount. As long as we are not over the allowed percentage for VA/Conventional Seller Concessions, can we apply the balance of the remaining credit as a principal reduction? We are trying to prevent reducing the loan amount at the 11th hour.
10/08/2017
If we want to provide notices of incompleteness and/or adverse action notices to commercial loan customers electronically. Am I correct in understanding we only need to obtain demonstrable evidence they have consented to receiving such notification electronically?
10/01/2017
If one person owns the house and is not married but both parties apply for a mortgage, who signs the mortgage?
09/24/2017
A customer completed a consumer application to refinance their vehicle. The lender did not run a credit report because after interviewing the borrower and running a value on the vehicle she determined the borrower did not have sufficient equity to refinance. She only has 'insufficient collateral' as a reason. A senior lender is telling her she needs to have two reasons and must run a credit report. Is there a regulatory requirement for two reasons or that a credit report MUST be run in order to give an adverse action?
09/24/2017
I understand that Reg CC does not apply to CDs. However, is it acceptable to place holds on CDs anyway?