Most Popular Lending Content
CTR Requirement for Spouses/Joint Account
12/08/2019
I need to know in this scenario if a CTR is required for the husband? The wife and husband come into the bank. The wife conducts a deposit to her personal (individual) account of $8,000 in cash. Then she conducts a deposit into the joint account (with her and husband) for $2,600. In my mind a CTR only needs completed on the wife because the wife is benefiting and conducted the $10,600 deposit. The husband did not conduct either transaction and is only benefiting from $2,600. Is my thinking correct? If required, please explain why a CTR is needed for the husband. Also, if a CTR is needed for the husband, I would like for you to consider this same scenario but without the husband present for the $8,000 deposit to the wife's account. When he enters the bank to make a $2,600 deposit to the joint account and we tell him we need to complete a CTR, wouldn't we be breaching customer information to tell him it is because his wife made a large cash deposit to her personal account early in the day?
HMDA- Include Savings Account When Reporting?
12/08/2019
I have a loan secured by a dwelling and a savings account. According to the HMDA commentary, I include the savings account when computing the CLTV. Okay, that's clear enough. My question is, do I include the savings account in reporting property value? Do I only include real property?
Home Equity Rate Special Disclosure Details
12/08/2019
Can we remove some of the details in a home equity rate special disclosure for billboard advertising and replace with a toll free number?
Commercial with Collateral as Operating Interest
12/08/2019
I have a commercial loan with collateral as "operating interest in wells." Do we need a mortgage, UCC or both to perfect a security interest in this? Also, is this collateral even considered real estate collateral?
Marketing service agreements can spell RESPA trouble
12/08/2019
We have been informed that marketing service agreements are illegal. We have a provider that is proposing a third-party agreement. He says this arrangement is not a marketing service agreement and is therefore legal. Your thoughts?
