Monique Reyna

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Servicing Compliance Webinar Series: Adverse Action Requirements

It’s more than just saying “No” When are adverse action notices required? Adverse action notices requirements for denied deposit accounts Adverse action notice requirements for commercial customers Notice of incompleteness requirements How should files be documented when a customer withdraws an application. What’s the difference between a withdrawn application and an application which was approved …

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HMDA Reporting Requirements: Business Purpose Loans

The passing of Senate Bill 2155 adds another level of complexity to an already complex Regulation. The Bill exempts institutions that originate fewer than 500 closed‐end loans or open-end lines of credit in each of the two preceding calendar years from reporting certain HMDA data points. This “relief” spurred the question, “What and how do …

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HMDA Reporting Requirements: Business Purpose Loans

The passing of Senate Bill 2155 adds another level of complexity to an already complex Regulation. The Bill exempts institutions that originate fewer than 500 closed‐end loans or open‐end lines of credit in each of the two preceding calendar years from reporting certain HMDA data points. This “relief” spurred the question, “What and how do …

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New Rule for Using Closing Disclosure When Resetting Tolerances

On April 26, 2018, the CFPB issued a final rule addressing utilization of a Closing Disclosure to reset tolerances under the TILA‐RESPA Integrated Disclosure Rule (TRID). Under the current regulation, a creditor may only use a Closing Disclosure to reset tolerances if there are fewer than four business days between the time the creditor is …

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