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Compliance Q&A: Flood Insurance for Detached Structure

Breaking, Compliance Q&A, Publications
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

Breaking, Compliance Q&A, Publications
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

Breaking, Compliance Q&A, Publications
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: Regulation D and Reserve Requirements

Breaking, Compliance Q&A, Publications
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

2019 Regular Session: Session Recap

Breaking, Capitol Notes, Politics, Publications
The 2019 Regular Session of the Alabama Legislature ended on May 31. The first regular session of this legislature’s four-year term, and indeed the very first session for many newly-elected legislators, was punctuated with many more “big-ticket” items than might normally be expected. Throughout ...Read More

Compliance Q&A: Web Site Regulatory Considerations

Breaking, Compliance Q&A, Publications
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

2019 Regular Session: Week 11 Recap

Breaking, Capitol Notes, Politics
The 2019 Regular Session will end today – Friday, May 31 – two legislative and 19 calendar days ahead of schedule. But as senators and representatives prepare to head home, plans are already being made for their return to Montgomery for the second special ...Read More

Changes Coming to “Change in Control”

Board Briefs, Breaking, Legal, Publications
By Jenny McCain In late April, the Board of Governors of the Federal Reserve System approved a notice of proposed rulemaking that would revise the Federal Reserve’s “control” rules under the Bank Holding Company Act of 1956 (Regulation Y). These rules that establish the ...Read More

Compliance Q&A: Commercial Lines of Credit

Breaking, Compliance Q&A, Industry Reports, Publications
Question: We have two commercial lines of credit that originated in 2016 but were increased by $200,000 each in 2019. We did not have new disclosures signed, and we simply executed a loan modification for the loan amount increase to both files. Should these ...Read More

2019 Regular Session: Week 10 Recap

Breaking, Capitol Notes, Politics, Publications
The first line of last week’s Capitol Notes remains the same for this week’s edition: “The calendar giveth, and the calendar taketh away.”  But this time, the “calendar” in question is not the one that determines when the Legislature is or will be in ...Read More
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