Compliance Q&A | Alabama Bank News

Compliance Q&A: PPP Application and Expired ID

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Q: The bank has received an application for a Paycheck Protection Program (PPP) transaction. The beneficial owner of the business is not a signor or guarantor. His ID provided is expired and he doesn’t wish to provide a new copy. Is this a BSA violation if ...Read More

Deposit Holds

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Q: If we doubt the collectability of a check that a customer presents to the Bank, are we able to put “an indefinite” hold on the funds? A: While Reg. CC does not specify the allowable duration of an exception hold for this reason, the Reg. ...Read More

Compliance Q&A: HMDA Reporting Question

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Question: This is a HMDA question. Borrower was scheduled for closing, but because a home inspection that the borrower ordered did not go as they planned, the borrower ended up cancelling closing. The bank did not require this inspection and all underwriting conditions had ...Read More

Breaking, Compliance Q&A, Publications

Q: This is a CARES Act question on credit bureau reporting for consumer-purpose loans. For those loans that have requested forbearance or other payment accommodations during the pandemic, we are not reporting those accounts as late (nor charging fees). However, if a loan does go ...Read More

Compliance Q&A: PPP Loan Reporting to Credit Bureaus

Compliance Q&A, Publications

Q: Are banks required to report SBA Paycheck Protection Program (PPP) loans to the credit bureaus? I thought that SBA 7(a) loans are required to be reported, but I don’t know if this extends to PPP loans. A: You are right that there is a general ...Read More

Compliance Q&A: Reg D Amendments – Temporary or Permanent?

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Question: Regarding the recent Regulation D amendments, are these temporary or permanent changes? Answer: As the interim final rule is currently written, these changes do appear to be permanent, and not tied directly to the current COVID-19 pandemic: “In January 2019, the FOMC announced ...Read More

HMDA Partial Exemption

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Q: Our bank qualifies for the HMDA partial exemption. Some of the data points that we are exempt are things we don’t use, like credit scores or automatic underwriting systems. So in reporting these data points, should I report “Exempt” or “Not applicable” in ...Read More

Podcasts and RESPA

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Q: What type of concerns should the bank consider if we decided to host a podcast with one of our mortgage loan originators and one of his friends who is a realtor? Currently, the plan is for the podcast to discuss the housing market, ...Read More

HMDA and Automated Underwriting System Reports

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Question: In some cases, our bank pulls an Automated Underwriting System (AUS) report, but ultimately not used in making the credit decision. Instead, the application is manually underwritten, and those results are used to make the credit decision. For HMDA purposes, do we still ...Read More

Compliance Q&A: Six Transaction Limit and Reg D

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Question: In regard to the six-transaction limit imposed in Regulation D, can a bank reduce this limit to only two transactions? Answer: Yes, the bank may set stricter limits than required under Reg. D. There is not a prohibition in doing using a ...Read More

Compliance Q&A Archive