Compliance Q&A Archive

Question: I have a quick question related to Regulation D and reserve requirements. If we offer commercial escrow services to hold funds for two or more parties, are these funds held in escrow generally subject to Reg. D?   Answer: Yes, escrow funds are specifically included in the definition of ...Read More

Question: For examination purposes, should we be logging all changes to our website or just the ones related to compliance?   Answer: Since the bank’s website is generally considered an advertisement and sometimes contains disclosures required by federal regulations, the bank would want to ...Read More

Question: I have spent the afternoon looking for a simple “definition” of what a distressed and underserved community is. I have found bits and pieces, and I have found the updated lists for 2018, but we are undergoing some policy updates, and would like ...Read More

Question: By what day do we have to file the continuing activity SAR? Is it Day 90 or Day 120?   Answer: The guidance provides that “Financial institutions with SAR requirements may file SARs for continuing activity after a 90-day review with the filing ...Read More

Question: With regard to the FDIC’s Part 350 Annual Disclosure Statement rescission, would it only apply to one of our charters or would it apply to the holding company and everything under it as a whole? We are two chartered banks under one holding ...Read More

Question: When is the deadline to provide a PMI notice of cancellation/termination? Answer: Assuming this is subject to the Homeowners Protection Act, the bank has 30 days after the PMI relating to a residential mortgage transaction is canceled or terminated to send out a ...Read More

Question: We are selling one of our branches next month. The branch only has one HMDA loan to date. Do we need to report that loan on the HMDA LAR? The bank that is purchasing the branch is not a HMDA-reporting bank. Answer: Assuming ...Read More