With the deadline for reporting entities to register their beneficial ownership information (BOI) with FinCEN’s Beneficial Ownership Secure System (BOSS) just three weeks away, the U.S. District Court of Eastern Texas issued a preliminary injunction blocking the implementation of the Corporate Transparency Act (CTA) citing that the Act is unconstitutional. TCA – A Better Way!

Does Lender Paid Mortgage Insurance (LPMI) and compliance with 12 U.S.C. 4905(c)(2) apply to HELOCs?

By Michelle Strickland | December 10, 2024

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What is a financial institution’s (FI) responsibilities as it relates to legal entities registering Beneficial Ownership information with FinCEN? Can we access the system now? Do we need to do anything differently?

Can our designated SAFE officer be an active loan officer that is currently producing loans?

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?

Is there any additional fair lending analysis that an institution should consider performing to ensure awareness by the institution?

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?

Does our institution have to open accounts for nonresident aliens or resident aliens (NRA/RA)?

When should our (Compliance, BSA, Fair Lending, Other) Risk Assessment be updated?

An institution allows service charges to overdraw our checking accounts but not our savings accounts. Should that be in our disclosures somewhere?

Beneficial Ownership Injunction

Does Lender Paid Mortgage Insurance (LPMI) and compliance with 12 U.S.C. 4905(c)(2) apply to HELOCs?

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