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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...read more
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,...read more
If you are a lender and you make closed-end, multiple advance loans to construct a consumer's home, you need to be aware of the TRID requirements and how they can impact the transaction. Unfortunately, it’s not quite as straightforward as other types of...read more
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”. ...read more
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...read more
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...read more
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....read more
Question: How do you complete Part I of a CTR for deposits into a joint account? Answer: When a deposit is made into a joint account, it is presumed to be made on the behalf of all account holders because they all have access to the funds. So,...read more
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...read more
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...read more