Industry Reports Archive

Question: Our bank has an affiliate that purchases account receivables. The affiliate orders consumer reports in order to conduct their business. One of their customers applied to our bank for a commercial loan. The affiliate, having obtained a credit report on the guarantor, provided ...Read More

by Rob Nichols If you are like many of the hundreds of bankers I have talked to since joining ABA three years ago, odds are you have an issue with your core provider. Yes, these companies are critical partners, and they deliver many excellent ...Read More

Question: HELOCs and escrow for flood–are they always exempt even if in 1st position? Answer: Yes, that’s correct–there’s a specific exemption for HELOCs in and of themselves: 339.5   Escrow requirement. (a) In general—(1) Applicability. Except as provided in paragraphs (a)(2) or (c) of this section, an ...Read More

Question: I pulled a flood certification in which there is one parcel of land but multiple, nonresidential buildings on that piece of land. The provider did not include a schedule of the buildings. All the buildings are in a flood zone, and the provider ...Read More

Question: Under Reg. DD, if a time account product is advertised generally is there a requirement to provide the term for CDs if a specific CD product is not advertised, and instead, simply that time accounts are among products offered? Answer: No, you’re not ...Read More

Question: For the Reg. DD – “indoor signs” exception in Section 1030.8(e)(2), I see that indoor signs are exempt from: permissible rates, when additional disclosures are required, bonuses, and certain media exemptions. My question is whether “when additional disclosures are required” includes, for example, an ...Read More

by James H. White, III Author’s note: The following is a memorandum from an investment bank to a hypothetical bank client faced with the possibility of a dissent and appraisal action in connection with a sale of the bank. Confidential Memorandum To: Community Banker ...Read More