Publications Archive

The Alabama Legislature gaveled in to begin the first year of its new quadrennium on Tuesday  The first day of the session culminated in a joint session where Gov. Kay Ivey presented out her agenda during her State of the State address. Ivey urged ...Read More

Q. Does RESPA require that we collect a cushion for escrow accounts? How large of a cushion must be collected? A. RESPA allows you to have up to 2 months’ cushion in an escrow account but doesn’t *require* that you have 2 months’ cushion. ...Read More

Q: If an account has multiple Pod beneficiaries on it and one beneficiary passes before the account owner, would the remaining Pod beneficiaries will receive the funds in the account upon the death of the account holder? In other words, none of the funds ...Read More

Q: Can a large deposit hold be placed on a next day item (cashier’s check) for the amount over $5,525? A: Yes, Reg CC allows this for cashier’s checks or treasury checks. Members commonly believe that they cannot place any exception hold on a ...Read More

Q: Would it be a requirement of any regulation for an institution to get a written cancellation request from a borrower to cancel automatic loan payments from a deposit account? We hold the Note and the account. Do we need the request to be ...Read More

Q:  If an individual named as a beneficial owner of a new legal entity account is an existing customer of the covered financial institution subject to the financial institution’s CIP, is the bank still required to identify and verify the identity of this individual ...Read More

QUESTION: For a TRID construction loan disclosed as two transactions, what should we disclose as the interest rate if it’s variable we don’t know what the rate will be during the permanent phase? ANSWER: If it will have an adjustable rate and the rate ...Read More