Compliance Q&A | Alabama Bank News

Compliance Q&A: Deferred Student Loan Payments

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Question: I’m not sure how to handle deferred student loan payments. I have a borrower that is working as a teacher and stated that her student loans would be paid for by the state. Does Appendix Q state that I can in essence ignore ...Read More

COMPLIANCE Q&A: SCRA and Proof of Military Service

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Question: For SCRA purposes, if a customer we know has been called into service comes into the bank to lower their rate, does the bank have to require proof of military service? Answer: No – there is not an actual requirement to collect or ...Read More

COMPLIANCE Q&A: Commercial Loans & HMDA Reporting

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Question: We have a commercial loan transaction where the borrower is purchasing a commercial building and repurposing it into 18 residential condos. Is this loan HMDA reportable? Answer: Unfortunately, the regulation does not specifically address the situation of a non-residential building is being ...Read More

Compliance Q&A: POS Transaction Dispute

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Question: If a consumer is disputing a POS transaction and it is not fraud (i.e. merchandise never received, service canceled, and company debited account or any other reason than a fraud transaction), are we required under Reg. E to give provisional credit while we ...Read More

Compliance Q&A: Multi-account, Multi-business CTR

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Question: John Doe owns 3 different stores. A store clerk of one of the businesses made all the deposits with one teller at one time. All three of the organizations are operated independently of one another: A corp. acct. # 12345 had a cash-in ...Read More

Compliance Q&A: Flood Insurance

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Question: We have a situation where a commercial borrower is purchasing two commercial properties that are in a flood zone. His insurance agent stated that he cannot purchase flood insurance on the properties in question until he owns the properties. We are doing the ...Read More

Compliance Q&A: CD Early Withdrawal Penalty

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Question: Is there a regulatory requirement to charge a 7-day early withdrawal penalty on a certificate of deposit (CD)? Answer: In the first week after a CD is created, there must be an early withdrawal penalty of at least seven days’ simple interest ...Read More

Compliance Q&A: Flood Insurance for Detached Structure

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Question: We have a property that is partially in a flood zone. The house on the property is not in a flood zone, but the barn on the property is in a flood zone. Do we have to require flood insurance for the barn? ...Read More

Compliance Q&A: Inheritance, Demolition & HMDA

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Question: If someone inherits a house and has plans to demolish it and build another house, what is the HMDA purpose? Answer: There is no bright-line rule in the regulations or guidance that delineates when a loan like this crosses the line between ...Read More

Compliance Q&A: Temporary Branch Closure Notification

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Question: If we need to temporarily shut down one of our branches to treat for dangerous mold, do we need to give any kind of notice to our regulator? Answer: At the federal level, there’s a specific exemption for temporary closings that are ...Read More

Compliance Q&A Archive