We are taking as security a condo unit in a residential structure. However, the unit is not used as a dwelling. It has a commercial purpose, such as, a doctor's office or a showroom or as a model. Would this loan be HMDA-reportable?
A question about CTR exemptions. We have a customer who owns a bowling alley. He has the bowling lanes, the pro shop, the snack bar and a children's party room organized as four separate businesses, each with its own tax ID number. Invariably, deposits are made for all the businesses at the same time, so they are aggregated and reported on a CTR when the cash amounts exceed the 10K threshold as the same individual makes all the deposits. Is it possible to exempt these businesses even though individually none of them ever exceeds the 10K reporting threshold? I assume that we would have to file a separate exemption form for each business.
Does the BSA regulation require testing employees? A few years ago one of our examiners said we should incorporate testing into our training. I can't find this in the reg.
I have an existing mortgage on land. We are disclosing a construction loan. Should the security interest description in the fed box show purchase money AND real estate or simply real estate and does that really matter. The assumption clause is there either way.
We are considering taking loan applications online. What are some key things that need to be considered as we go through this process? What questions should be asked?