Q&A

Should a bank remove any language regarding disparate impact from their policies and fair lending risk rating since many of the regulators are removing this language from their compliance exam manuals since it is not a priority?

Q&A / By Margaret Dolinger

Should a bank remove any language regarding disparate impact from their policies and fair lending risk rating since many of the regulators are removing this language from their compliance exam manuals since it is not a priority? Read More »

Is an Affiliated Business Disclosure required for a commercial loan?

Q&A / By Kim Simmons

Is an Affiliated Business Disclosure required for a commercial loan? Read More »

Has your institution updated its BSA/AML/OFAC policies and procedures to remove outdated FinCEN and OFAC references?

Q&A / By Jennifer Rura

Has your institution updated its BSA/AML/OFAC policies and procedures to remove outdated FinCEN and OFAC references? Read More »

On a commercial loan do we need to provide a credit score disclosure (CSEN)? For example, we have a 1-4 family dwelling investor loan program where we have customers that are looking to purchase, say a 3 flat, either in their individual name or in the name of an LLC and they provide a personal guaranty. Do we need to generate a credit score disclosure for these if we pull credit report with credit score?

Q&A / By David Mulkerin

On a commercial loan do we need to provide a credit score disclosure (CSEN)? For example, we have a 1-4 family dwelling investor loan program where we have customers that are looking to purchase, say a 3 flat, either in their individual name or in the name of an LLC and they provide a personal guaranty. Do we need to generate a credit score disclosure for these if we pull credit report with credit score? Read More »

If a customer’s Cash App account is hacked and there are fraudulent transfers, can we tell the customer that they have to contact Cash App?

Q&A / By Brian Crow

If a customer’s Cash App account is hacked and there are fraudulent transfers, can we tell the customer that they have to contact Cash App? Read More »

Are there any active Special Measures?

Q&A / By Brenda Payne

Are there any active Special Measures? Read More »

We are originating a bridge loan to refinance existing obligations and provide funds for the down payment and closing costs associated with a purchase money mortgage for a new primary residence. The loan is secured by the borrower’s current primary residence and will be paid off upon the sale of that property. As such, it is exempt from HMDA reporting requirements. We would like clarification on whether we are still required to collect Government Monitoring Information (GMI) under Regulation B. Does Regulation B also consider this type of loan to be temporary financing and therefore not subject to §1002.13?

Q&A / By Angela Rankin

We are originating a bridge loan to refinance existing obligations and provide funds for the down payment and closing costs associated with a purchase money mortgage for a new primary residence. The loan is secured by the borrower’s current primary residence and will be paid off upon the sale of that property. As such, it is exempt from HMDA reporting requirements. We would like clarification on whether we are still required to collect Government Monitoring Information (GMI) under Regulation B. Does Regulation B also consider this type of loan to be temporary financing and therefore not subject to §1002.13? Read More »

Are there any requirements for specific disclosures on periodic home equity loan statements for consumers in bankruptcy? 12 CFR Part 1026.41 (Regulation Z) has requirements for closed-end consumer credit transactions but unclear about HELOCs.

Q&A / By Michelle Strickland

Are there any requirements for specific disclosures on periodic home equity loan statements for consumers in bankruptcy? 12 CFR Part 1026.41 (Regulation Z) has requirements for closed-end consumer credit transactions but unclear about HELOCs. Read More »

The FDIC logo change was pushed until May 1, 2025, but my institution was wondering if the logo on our printed rate sheets given to customers upon request needs to be updated. My understanding is that the gold/black signs we have at the teller windows, and banker desks are NOT changing, and I think printed logos aren’t changing, but really, it’s mainly about the digital channels – and those need to be navy blue and black. So, if I’m correct, then the rate sheets do not require updates?

Q&A / By David Mulkerin

The FDIC logo change was pushed until May 1, 2025, but my institution was wondering if the logo on our printed rate sheets given to customers upon request needs to be updated. My understanding is that the gold/black signs we have at the teller windows, and banker desks are NOT changing, and I think printed logos aren’t changing, but really, it’s mainly about the digital channels – and those need to be navy blue and black. So, if I’m correct, then the rate sheets do not require updates? Read More »

When will an institution have to comply with the upcoming 1071 Small Business Lending reporting requirements?

Q&A / By Sara Kirkpatrick

When will an institution have to comply with the upcoming 1071 Small Business Lending reporting requirements? Read More »