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Don’t Miss the Boat with Consumer Complaints!

Dave and Jerod recently taught at the ABA Compliance School in June.  Between the two of them, they still managed to sit in on as many breakout sessions as they could.  One observation they both made when comparing notes, was that you don’t want to miss the boat when...

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OFAC Amendments

OFAC recently published an Interim Final Rule to amend its Reporting, Procedures and Penalties Regulation (31 CFR part 501).  This section deals with the reporting, recordkeeping, and licensing requirements for OFAC’s economic sanctions programs.   In the past,...

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Periodic Statements for a Reaffirmed Loan

Question:  How should we handle the periodic statement requirements once a customer has reaffirmed a loan after bankruptcy?     Answer: You must go back to providing regular periodic statements, however you would qualify for a “single-statement exemption”. ...

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TRID for Beginners

What is an intent to proceed? Where does it go? How do I document it? Why do we even have to do it? If you're a seasoned TRID veteran, you very likely know the answers to those questions. It's really not that complex, but if you're brand new to TRID, something as...

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Suspicious Activity Reports & Computer Intrusion

Question:  Should an attempt to hack into the bank’s website be reported as computer intrusion on a SAR?     Answer: No, an “unauthorized electronic intrusion” does not include attempted intrusions of websites or other non-critical information systems of the...

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Regulation CC Final Rule Issued

It seems like we’ve been waiting FOREVER for the funds availability sections of Regulation CC (Subpart B) to be updated. Well, on June 24, 2019, the CFPB and Federal Reserve finally issued a Final Rule.  While it’s not everything we were hoping for, it is a start....

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TRID: Construction Loan Escrow Payment

Question:  On a construction-permanent loan (one closing), should the escrow payment be reflected in the first column of the Projected Payments Table?     Answer: It depends. When disclosed as a single transaction and the construction phase is less than a full...

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Determining Insurable Value

Question:  In our last exam, we were told to look at the appraisal’s replacement cost value or comps (if listed) rather than a tax assessed value when determining the insurable value of residential properties.  Since the appraised value/comps are often older than the...

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