Can a legal hold be placed on a checking or money market account for loan collateral?
I assume that on the loan side we need to determine whether the customer is an MSB and get all the required documents. However, from a practical standpoint, how does one monitor such a relationship if all they have with us is a loan?
Regarding FinCen 314 (a) requests. If we have a system that is able to keep a database of all FinCen inquiries and scan new accounts to that list, is that allowed? Or are we supposed to just scan our current clientele and not worry about any new accounts after the check date?
We have a future advance clause in our first mortgage for x amount of dollars. We then use this to secure personal notes. Should these personal notes have a mortgage servicing disclosure, RESPA, flood determination form?
Are we supposed to complete annual reviews on Phase I exempt customers (school districts, county governments?)