We have several loan production offices. They don't have cash drawers, are not listed as branches, and they don't service the deposit customer walking in off the street. Do we need signage such as the FDIC stickers? What if a courier for the bank picks up some proof work where only our employees make deposits instead of running to a branch?
If the HMDA rate spread exceeds the 3% threshold on a first mortgage, other than reporting it, is the lender obligated to provide any disclosures to the borrower as HOEPA requires?
When doing a renewal, with or without new money, either a term loan or line of credit and the original purpose was either purchase, refinance or home improvement secured by dwelling is it HMDA reportable? The customer is going to sign a new Promissory Note but the account number and the note number is going to be the same.
We handle FHA/VA loans where we do not make the credit decision. The Reg says we report HMDA if we make the decision, but HUD is telling us to report these in addition to the entity making the decision. Should we be reporting them in addition to the lender making the decision?
I am looking for a CRA Officer Policy and Procedures. Something that spells out what this person holding the title of CRA Officer should be doing.
Year-End Developments & Predictions
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?
I am starting a new position as a lending manager. I am rusty with the regs. Where could I go to get a printed version of the regs applicable to lending, and which ones would you recommend I read up on?
The Federal Reserve Board staff has held constant and issued a proposed update to Regulation Z's Official Staff Commentary in time for the holiday mail.