Would it be smart to seek out beneficiaries and/or successor custodians to reduce your abandoned property burden...or would that create a GLBA privacy violation?
It has been my experience that most financial institutions request a consumer sign a specific form (vendor developed; card processing developed; or internally developed) - what I would consider "industry standard." I have a client who was cited by the FDIC (who said "all" regulatory agencies are citing this as an issue) for "requiring the use of a particular form." Regulation E allows for requiring disputes be put in writing and signed, providing the investigation is not delayed if a written form is not received. The bank's process includes beginning the investigation upon notification (oral or written) and follows up with getting a specific form signed (card processor developed). Has anyone else heard of regulators citing for "required use of a specific form"? If the card processor requires disputes be submitted on their form, how can the bank complete the investigation process without "requiring" the use of a specific form?
What is deposit imaging software used for?
We use combined DTI for underwriting purposes. Regardless of whether joint applicants are married, unmarried, living in the same household, etc. we would need to be consistent with this underwriting practice and consider combined DTI? We shouldn’t look at individual DTI on unmarried joint applicants who for example don’t live at the same household?
Joint application is received by the bank with one applicant having excellent credit and the other having terrible credit. For AAN purposes, if we provide the specific reasons for turndown to the terrible applicant such as repossession, delinquent past/present credit obligations with others, etc. and then provide an AAN to the excellent applicant, we should re-state repossession, delinquent credit obligations, etc. on the excellent applicant’s AAN as well - even though these reasons don't specifically apply to the excellent applicant himself, but are the primary reasons for the turndown. Correct?