Publications Archive

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

Question: So I am aware of the two walls and a roof requirement in the flood regulations, but what if the building is on a dirt floor but secured to the ground with concreted post? Because there is no floor, does that negate the requirement ...Read More

Question: For HMDA reporting, the purpose is to construct 45 additional apartment units but collateral is existing 68 unit apartment complex and land where borrower will build the additional units. The payment terms are 24 payments of interest only thru 3/15/21 then payments of P & ...Read More

By Cathy Moore and Chris Hawkins On Aug. 26 the “Family Farmer Relief Act of 2019” (H.R. 2336) was signed into law, substantially increasing the debt limit for agricultural producers seeking to file for relief under Chapter 12 of the United States Bankruptcy Code. ...Read More

by Charles W. Prueter In 2007, a bankruptcy and securities law professor at Harvard Law School proposed the creation of a new independent federal agency to enforce consumer financial protection statutes and regulations and generally to regulate the financial services sector. The professor’s proposal ...Read More

Question:  The private flood insurance regulations have a provision requiring an insured to file suit not later than one year after the date of a written denial for all or part of a claim under a policy, but the policy we’re looking at does ...Read More

Question: This is regarding the recent threshold changes to Regulation CC. Since we have same-day availability and the amounts are actually in the customers’ favor, do we have to do a change notice to reflect the new funds availability thresholds? Answer: Yes, it would ...Read More