I have just been nominated compliance officer of a thrift at which I am a new employee (this is my 3rd week). I have 15 years previous banking experience in almost every department but never in compliance. Where should I start?
Is there any caveat in Reg O that would allow us to waive an inadvertent late fee on a loan for the interest of a director? I don't know of any, but if there is one I'd hate to prohibit the waiver!
One of our consumer officers made a loan to an employee and his 16 year old son as co-applicants. Of course, the 16 year old is well below the 18 year old limit for entering into a contract, so his signature is essentially worthless. My question is, are there any other issues we need to worry about - such as notifying the father that he alone is responsible for the loan and reporting the 16 year old's credit to credit reporting agencies.
Is there any problem with extending credit to a Bank employee that is secured by the vested portion of their ESOP (w/401k provisions) account?
An examiner (OCC) told me all employees have to be trained on each regulation every 18 months. Where can I find this requirement in the regulations?
Whether your institution's market area includes a piece of Indian Country or not, you can learn a lot from banking and economic development activities that are taking place now in Indian Country.
I have two questions regarding RESPA issues related to indirect home improvement financing. First, we are paying a broker - who is not an employee of the bank - for signing up contractors to submit credit applications on their customers to us. Since most of these loans are secured by a mortgage on a primary residence and we are paying the broker a percentage of total loan volume generated, how do we treat this with respect to the Good Faith Estimate and HUD-1A? Secondly, since we require hazard insurance coverage from an insurer chosen by the borrower, is it not permissible under RESPA to provide only an estimate of the annual hazard insurance cost on both the GFE and HUD-1A forms? We are being told that the GFE can reflect an estimate, but that the HUD-1A must be the actual annual premium amount being paid by a given borrower. This presents a problem, in that, since the program is indirect, we do not know what the actual premium cost is for any given borrower and , therefore, use an estimated cost amount on both documents. Are we in compliance?
Household International's Household Finance Corporation ("Household") has agreed to implement the following new initiatives in its HFC/Beneficial branch based businesses:
Our bank is considering providing an employee benefit which would reduce the closing fees when they finance a new home purchase or refinance their existing first mortgage. In particular, we are questioning whether the bank can pay for the outside costs such as attorney costs for title search and title insurance, appraisal fees, and etc. (for employees only) without violating any regulations.
I'm a new compliance officer and I need to know what regulations require employee training. I'm in the process of putting together a compliance training calendar for my bank.