Since the US District Court issued an injunction blocking the Corporate Transparency Act, what do we do if a customer refuses to provide their beneficial ownership information at account opening? Q&A / By Brian Crow Since the US District Court issued an injunction blocking the Corporate Transparency Act, what do we do if a customer refuses to provide their beneficial ownership information at account opening? Read More »
Is there any additional fair lending analysis that an institution should consider performing to ensure awareness by the institution? Q&A / By Margaret Dolinger Is there any additional fair lending analysis that an institution should consider performing to ensure awareness by the institution? Read More »
If a customer notifies an institution of unauthorized EFT transactions more than 60 days after the date of the statement when the first unauthorized EFT transaction occurred, what is the institutions responsibility concerning this claim? Q&A / By Steven Gust If a customer notifies an institution of unauthorized EFT transactions more than 60 days after the date of the statement when the first unauthorized EFT transaction occurred, what is the institutions responsibility concerning this claim? Read More »
Does our institution have to open accounts for nonresident aliens or resident aliens (NRA/RA)? Q&A / By Claire Sarzynski Does our institution have to open accounts for nonresident aliens or resident aliens (NRA/RA)? Read More »
When should our (Compliance, BSA, Fair Lending, Other) Risk Assessment be updated? Q&A / By Brenda Payne When should our (Compliance, BSA, Fair Lending, Other) Risk Assessment be updated? Read More »
An institution allows service charges to overdraw our checking accounts but not our savings accounts. Should that be in our disclosures somewhere? Q&A / By David Mulkerin An institution allows service charges to overdraw our checking accounts but not our savings accounts. Should that be in our disclosures somewhere? Read More »
Does Lender Paid Mortgage Insurance (LPMI) and compliance with 12 U.S.C. 4905(c)(2) apply to HELOCs? Q&A / By Michelle Strickland Does Lender Paid Mortgage Insurance (LPMI) and compliance with 12 U.S.C. 4905(c)(2) apply to HELOCs? Read More »
How should a CTR be completed when a customer takes cash back from a deposit? Would the cash out amount be listed in Field 27 as a withdrawal or a negotiable instrument cashed? Q&A / By Melissa Hoeft How should a CTR be completed when a customer takes cash back from a deposit? Would the cash out amount be listed in Field 27 as a withdrawal or a negotiable instrument cashed? Read More »
What are the timing and content requirements of an escrow closing notice? Q&A / By Monique Reyna What are the timing and content requirements of an escrow closing notice? Read More »
Can a financial institution have all borrowers waive the Appraisal Delivery or is there special circumstances required to waive the Appraisal Delivery timing requirements? Q&A / By Sarah McCaslin Can a financial institution have all borrowers waive the Appraisal Delivery or is there special circumstances required to waive the Appraisal Delivery timing requirements? Read More »