Implementing the changes to HMDA is not going to be easy.
What are the regulations in regards to offering an electronic savings account? We would like to offer one that limits the deposits to electronic only and encourages ATM withdrawals, We would target customers with electronic Social Security or SSI payments into their accounts.
If a customer owns the land that a single wide mobile home is located on, and the loan will be secured by both the "Land" and the mobile home, is this type of loan covered under RESPA and REG Z Section 226.19? What disclosures would be required?
The Comptroller of the Currency has put forward a revolutionary idea: consumer disclosures that are easy to prepare and understandable to consumers. What a novel concept.
The bank would like to disclose "security reasons" as the reason not to list transfer limitations in its Reg E disclosures. I see model language (For security reasons, there are limits on the number of transfers you can make using our [terminals] [telephone billpayment service] [pointofsale transfer service].) for the "frequency" of transfers but not for the "dollar amount" of transfers. Can you use similar language for the dollar amount of transfers?
We are getting hit hard with fraudulent new accounts who deposit $50 to open the account, then deposit a bogus or NSF $9,000 check two days later and withdrawal that amount before the check is returned. Any ideas how to legally stop this from happening without offending legitimate new customers?
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.
I remember reading article concerning a combined note and disclosure. I am unable to locate the article on the site. Could you please assist me in finding the article?
The Loan Department at my bank wants to implement a new fee for customers changing collateral, i.e., vehicles on an existing loan. Evidently, they have a few customers who buy and sell vehicles quite often and instead of doing a new loan, the bank simply changes the collateral securing such loans. If this is done for all customers who change collateral, do we still have a problem? Are we required to do new disclosures?
I just read in ABA Bankers News, Volume 10, Issue 13 front page about Examiners asking for our "Information Security Risk Assessment". I am confused as to what the examiners are looking for.