Library

Keep up to date with our Regulatory Compliance Manager Subscription Service

Learn More

If there’s a subject that you’d like to research, please call 800-934-REGS or email us [email protected] and we’ll get the information to you.

Question and Answer

Under HMDA, Government Monitoring is not collected when the applicant is not a natural person. I understand that corporations, partnerships, etc. are not natural persons. However, how do I report a loan where the borrower is a non-natural person and the co-borrower is a natural person? Do I report both as “not applicable”? What if the officer/partner signs as Manager or President? Does that make a difference?

By | December 16, 2025
Question and Answer

When should I be listing an alternate name for a CTR or a SAR? Does this alternate name need to be verified?

By | December 15, 2025
Question and Answer

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?

By | December 12, 2025
Question and Answer

Is an Affiliated Business Disclosure required for a commercial loan?

By | December 12, 2025
Question and Answer

Has your institution updated its BSA/AML/OFAC policies and procedures to remove outdated FinCEN and OFAC references?

By | December 11, 2025
Question and Answer

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?

By | December 10, 2025
Question and Answer

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?

By | December 9, 2025
Question and Answer

Are there any active Special Measures?

By | December 8, 2025
Update

More Updates to the FDIC Official Signage Rule

By | December 5, 2025

The FDIC delayed the implementation date for the updates to 12 CFR 328.4 (Signs for automated teller machines and like devices) and 328.5 (Signs for digital deposit-taking channels) which were originally to go into effect as of January 1, 2025, postponed to May 1, 2025 and were postponed again to March 1, 2026. TCA – […]

Question and Answer

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?

By | December 5, 2025

Do You Need Compliance Help?

We’re here to review your current compliance strategy and help you find A Better Way to manage risk.

Phone

800-934-REGS

/

Email for Non-Confidential Information Only

[email protected]

/

Office Location

2021 Midwest Road, Suite 200,
Oak Brook, IL 60523

Endorsed By