Compliance Q&A Archive

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

Question:  Our current SCRA procedures say that the interest rate should be retroactively applied to the date on which the service member was called to military service. In the case of a member of the reserve, though, would that be the date that they ...Read More

Q. Our customer received a phone call from someone telling the customer that the customer’s computer was about to be hacked. The person convinced the customer to allow a remote logon to the customer’s computer to “stop the hacking process.” In this process, the ...Read More

Q. We have a designated disaster area close by and were wondering which activities in these areas would qualify for CRA Community Development? A. There are a variety of activities relating to designated disaster areas (DDA) that may qualify. Loans, investments/donations, and services that ...Read More

Q. Is the Bank required to report SBA loans to the credit bureaus? A. The SBA Standard Operating Procedures do set out requirements to report SBA loans to credit reporting agencies, starting on p. 28 here: “…2. Reports to Credit Reporting Agencies In accordance ...Read More