07/07/2003
We have a question regarding disclosing contents of a credit report. A 15 year old opens a checking account. The bank pulls a credit report which contains some adverse information. The credit file was not inspected. Can the information be disclosed to the child's parent or legal guardian so that they can get the problem corrected? We have not been able to find anything that addresses minors, can you point me in the right direction.
07/07/2003
If an application is denied for reasons other than credit, but a credit report was pulled, are we required to disclose the Credit Bureau's Address?
07/07/2003
We have utilized a prefab fair lending policy from a nationally known compliance consultant. In this policy it states that "The bank shall devote special attention to the credit needs of the low and moderateincome neighborhoods within its community (as defined in its CRA policy and CRA statement). To the extent possible consistent with safety and soundness, the bank shall make credit available on more favorable terms than it otherwise would offer to residents and owners of small businesses (and small farms) within such low and moderateincome neighborhoods." This was intended to convey CRA efforts. The examiners are looking at it as a violation of REG Breverse redlining. In speaking with the national vendor that wrote this policy, they see nothing wrong with it and several banks across the country use it and have had no problems. What is your opinion and do you know of any written info to back it up?
07/07/2003
Do you know or know where I can find the industry average for credit card 30+ delinquency and charge-off percentages?
07/07/2003
Is it possible to link overdraft protection on a Business DDA account with automatic transfers instead of establishing a separate business line of credit with fund transfers?
07/07/2003
What are the requirements to perfect a security interest in a life insurance policy? We are going to get an Assignment/Acknowledgment from the insurance company, but do we need to file a UCC-1 on the policy itself?
07/07/2003
If we offer a program of a reduced-rate loan if customer puts the loan payments on auto debit out of a checking or a savings account, what kind of disclosures would we need to give and is there a form available?
07/07/2003
If, when doing a mortgage refinance, the bank has collected fees for appraisal, credit, flood, and rate lock, and indicated that these fees are non-refundable, but the borrower rescinds--do the fees have to be refunded, if the costs were actually incurred on the borrower's behalf?
07/01/2003
There is nothing quite like going through a mortgage settlement to get a fresh perspective on compliance, regulatory burden, and paperwork in general.
07/01/2003
Each year the Federal Reserve Board updates the Official Staff Commentary to Regulation Z, Truth in Lending.