Can a flood civil money penalty cost six figures or more?
We have a customer who passed away. The customer was the sole owner of two corporations. The first corporation is a real estate holding company. There is a loan and DDA to this entity. The loan payment is auto-debited from the DDA. There is a second DDA to the other entity, also a corporation, which is to the operating company. Can we continue to pull the payments from the DDA to keep the loan current until the estate is settled and the loan paid off?
Given all other HMDA reporting criteria being met, would a bungalow colony be considered HMDA reportable?
For banks that provide combined ECOA-FCRA disclosures, is it standard practice to “Check the 1st Box” and provide FCRA credit score information if the decline reason is not based on the consumer report, but some other factor? (i.e. insufficient collateral, product not offered, out of lending area) Do other banks do this? We understand that we do NOT have to “Check the 1st box” and provide credit score information if it was NOT used in making the adverse decision, but what would be the risk to provide this information in the above cases?
Is flood insurance compliance complicated?