08/13/2012
We are completing our annual due diligence review of customers exempt from CTR filing requirements and have discovered a customer who no longer meets all the criteria for exemption. Are we required to obtain a back filing determination for their activity in the preceding year?
08/13/2012
Do you have to disclose owner's title insurance on the Good Faith Estimate for a construction-permanent loan?
08/13/2012
We have a borrower who is refinancing his home, which was previously in a flood zone. The prior Flood Determination is less than seven years old, so I know we can use the previous Determination. Must we send a new Flood Notice to be signed?
08/06/2012
Are business account transactions subject to Regulation E?
08/06/2012
Would the reduction in a Commercial LOC be considered an adverse action requiring notification to the borrower?
07/30/2012
Can a partnership between a husband and wife have a NOW account? Can an LLC with only one member have a NOW account?
07/30/2012
Are Remote Deposit customers' deposits subject to Regulation CC requirements?
07/30/2012
We are considering offering a CD at a promotional rate. What type of guidance is there regarding the maximum penalty we could impose on an early withdrawal?
07/23/2012
When must a mortgage loan originator provide his or her unique identifier to a consumer?
07/23/2012
We were advised that we should order joint consumer credit reports for unmarried applicants living at the same address. Does it follow that we should order individual reports for married applicants living at separate addresses? This would ensure that the determining factor is residence, not marital status.