Monthly Archive:: December 2019

By Maggie Thompson Somewhere along the way (perhaps, not-so-coincidentally, as we each made the transition from child to adult) the holiday season became one big ball of pressure—with financial worry at its core. Statistics seem to support that spending (and, often, overspending) plays a ...Read More

Question: We send disclosures electronically and can be notified when the borrower has not accessed them by the Loan Estimate (LE) due date. Are we required to mail the disclosures on that day if the borrower hasn’t accessed the electronic docs? They are telling ...Read More

Question: Is an “assumed” loan HMDA reportable? There was only one borrower when the loan was originated (not this year) and the loan was reported in that year. The Bank has now allowed another borrower to assume the note from the original borrower.   ...Read More

Question: Can you clarify all of the documents that the Board of Directors is required to review prior to approving the BSA/AML Policy?  Does the BOD need to review the Policy, Risk Assessment and Procedures as a total program review? Answer: Because procedures and ...Read More

Question: We were written up for the initial CD being sent via e-disclosure to a borrower that did not have E-SIGN consent. I am saying that sending via email was not an option for the borrower.  Is this correct? I did just look at ...Read More