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Vendor Guru Q&A - Operations

Electronic Management of SAR Files

Latest Operations - Real Estate Lending Topics

Privacy among applicants

06/03/2019

If credit is denied because of issues related to only one applicant, for example a charge-off, can we disclose that reason to both applicants, and do both applicants get an Adverse Action Notice?

Discrimination against the majority

05/26/2019

Has there been a case where a lender tried so hard to assist minority applicants that it had a fair lending issue with majority applicants?

AAN? We don’t make those loans.

05/19/2019

Our lender had a request for a reverse mortgage. He provided an Adverse Action Notice, but did he have to, since we don’t offer reverse mortgage loans?

‘Click me to enroll’ isn’t enough

04/28/2019

Our customers who want e-disclosures click on an “Enroll Me” link. Is that good enough for compliance?

Current Bureau Hot Topics

04/07/2019

Based on the CFPB's latest semiannual report, what are examples of topics of critical importance to the Bureau right now?

Who opens e-statements and who doesn’t

04/07/2019

If we send e-statements are we required to monitor whether they are being read, and if the customer is not opening them, do we have to revert back to paper?

Complaint retention

03/24/2019

How long should we keep typical complaint letters?

E-SIGN and demonstrable consent

03/24/2019

We like having customers sign up for Internet banking when they open their accounts. Is this acceptable for E-SIGN, or is more needed?

Complaint responses scripts

03/03/2019

Do you recommend having scripts to respond to complaints received over the phone and do you recommend taping the conversations?

Presidential reply to complaints

02/24/2019

I’ve always heard the bank president should reply to complaints. Why is it best for the president to do this?

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Premium Content View All

SAR Reporting: CREF?

If you don't know what CREF stands for, it is time to learn. It happens in the commercial lending department and involves real estate lending fraud.

Most Popular Operations Content

Conditions for customers making EFT claims

06/16/2019

When Reg E does apply, what kind of requirements can we place on the customer? Can we require that they file a police report or prove they have attempted contact with the merchant first?

Handling creditors of deceased customer

06/16/2019

If a creditor inquires about a debt owed how would it be handled with the Privacy Act?

Can a trust own a business?

06/16/2019

Can a trust be the sole owner of a business like a sole proprietor?

Return if Overdrawing? ACH Debit with "Reversal"

06/16/2019

If an ACH debit comes in with the word "reversal" in what I will refer to as the title, can we return it if it is overdrawing the account?

Vehicle title loans

06/16/2019

What is a vehicle title loan?

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