Regarding HMDA, we have two different answers as to what defines a Bridge loan. They are basically the same answers with one exception: if the loan is secured by BOTH dwellings (existing one and one to be purchased); OR if the loan is secured by ONE dwelling (either existing or one to be purchased). As I said, I understand consistency is the key to remaining violation free in this area, but again, I would like to know how the majority views this detail of a Bridge loan.
I have a note that references a Security Agreement but there is no Security Agreement attached. Instead there is a UCC that is being use as a Security Agreement. Is this okay, or should there also be a Security Agreement that references the UCC?
We are looking to provide the Board of Directors with an annual report card on our BSA/AML program (with information such as how many CTRs; we filed how many SARs; and how many SARs were investigated and not filed etc.) Are there any templates out there for this type of report to give us a starting point?
I exempted a customer last year after they met the Phase II requirements. Should I file on them this year until they meet the frequent transaction requirement of five transactions or are they exempt until they do not meet them for this year?
Could you please tell me of a source for BSA training for our Board of Directors?