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What do fair lending and disparate impact have to do with the new private flood insurance rules? July 1, 2019, is the “go date” for the new private flood insurance requirements, which basically say that if a borrower provides the bank with a private flood...read more
Question: We pulled a credit report and although the applicant’s credit history is not good, we did not use the applicant’s poor credit history in our decision to deny the loan request. Are we required to make note of this on the Adverse Action Notice? ...read more
Question: What if we have a private policy that meets all of the Biggert-Waters requirements except that the policy deductible exceeds the maximum NFIP deductible? Answer: You cannot allow a private policy to have a deductible that is higher than the deductible...read more
Question: I recently had lunch with a real estate agent to talk about doing some co-marketing. We discussed the potential RESPA concerns and decided to not move forward at this time. At the end of lunch, the agent picked up the check. Did we violate RESPA’s Section...read more
Can a customer dispute a debit card transaction or an ACH a year or longer after it happened? The answer is yes, they can! To understand this, we need to look at both Section 1005.6 and Section 1005.11 in Regulation E. Listen to the video as Dave...read more
Yesterday, the CFPB issued a proposal that seeks to make changes to the existing HMDA Rule. They also issued an Advance Notice of Proposed Rulemaking (ANPR) to solicit comments as to whether certain other changes are needed. The proposed changes...read more
Private Flood Insurance. Compliance Aid Statement Confusion.read more
We often get the question, “Can we rely on existing CIP information to satisfy the Beneficial Ownership requirements? In short, the answer is yes, but you do have to meet some specific criteria to be able to do so. Listen to the video as Jerod explains that...read more
When a customer disputes an electronic funds transfer, it’s not uncommon for a bank’s card processor to require that the customer first try to resolve the issue with the merchant, sign an affidavit or jump through other hoops. It’s important to point out that...read more
Do you have a borrower that wants to cancel the required escrow account on their Higher-Priced Mortgage Loan (HPML)? First you need to understand what your options are. Option #1 is that you don’t have to honor their request. You can require they keep...read more