Vendor Guru Q&A - Operations

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?

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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.

Must ACH authorizations be written?

11/17/2019

Does there always have to be a written authorization for an ACH transaction affecting a consumer’s account?

Check to Individual-Deposit in Living Trust?

11/17/2019

Can a check made payable to a individual be deposited into a account titled in their living trust. Please help settle this dispute.

Must banks make small business loans?

11/17/2019

Must every bank make small business or small farm loans?

What is your opinion of offering a checking account that offers add-on third party benefits as a feature of the account? Customers are only able to obtain the add-on services if they buy the account and pay the service charge disclosed for this product.

CRA credit for nonprofit loans

11/10/2019

Are loans to not for profits included in small business or small farm lending?

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