Compliance Q&A | Alabama Bank News

Compliance Q&A: Commercial Loans & Flood Insurance

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Q: Commercial Loan Scenario—Collateral is located in a SFHA, but is in a non-participating community. Because federal flood insurance would not be available, can the bank close the loan without flood insurance coverage? A: If the property is in a non-participating community, then flood ...Read More

Compliance Q&A: ATM Fee Notifications for Non-customers

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Q: Does our ATM have to notify a non-customer of the bank that our bank is going to charge a fee and what the fee amount is? A: Yes, this is an explicit requirement under Regulation E, as provided below: (b) General. An automated teller ...Read More

Compliance Q&A: Reg E and Electronic Statement Delivery

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Question: For the electronic delivery of a periodic statement under Regulation E, is the bank required to notify a customer that it is available? Answer: For customers that would like to receive their statements electronically, they must provide E-SIGN consent first–but once they provide ...Read More

Compliance Q&A: Join Accounts and Reg CC

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Q: We have a husband and wife who are opening a new joint checking account with our institution. The husband has had an individual account with us for a while, but the wife has never had an account with us. Can we still use ...Read More

Compliance Q&A: Regulation D and Transfers

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Q: If our bank chooses to continue to impose the six-transfer limit as it used to be set out in Regulation D, does a telephone transfer count toward the six transfers per month? A: Yes, in general, these would usually have been counted in ...Read More

Compliance Q&A: Adverse Action Reports

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Q: The bank is denying an application for a deposit account, but we did not pull a credit report to make this determination. Is an adverse action notice required? A: If the bank did not use a credit report to deny the deposit account ...Read More

Compliance Q&A: PPP Loan Forgiveness Applications

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Q: When can borrowers with Paycheck Protection Program (PPP) loans submit their loan forgiveness applications? A: As set out in Interim Final Rule #20, borrowers can submit a loan forgiveness application any time on or before the maturity date of the loan—including before the ...Read More

Compliance Q&A: HELOC Conversion and TRID Disclosure

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Q: Can the bank convert a HELOC that is getting close to its maturity date into a closed-end, amortizing loan without requiring TRID disclosures? A: Unfortunately, no–if during the loan term a HELOC is converted from open-end credit to closed-end credit, that would trigger ...Read More

Compliance Q&A: COVID-19 and Coding Forbearance

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Q: If our customer is on a COVID-19-related forbearance plan (and she was current before the bank agreed to the plan), do we use special comment code AW (affected by natural or declared disaster) and code CP (account in forbearance) and will either affect ...Read More

Compliance Q&A: Extension of Credit to Executive Officers

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Q: It is my understanding that the aggregate amount of extensions of credit to executive officers cannot exceed $100,000 for Regulation O purposes. If an executive officer has a loan that is guaranteed by FSA or SBA, is the guaranteed portion of that loan ...Read More

Compliance Q&A Archive