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Question and Answer

How does the Bank provide evidence that an Economic Development activity has a qualifying Community Development purpose?

By | December 22, 2025
Question and Answer

Our institution used to provide ATMs that accepted deposits and this is no longer available. Do we need to provide customers with a “Change in Terms” notification?

By | December 19, 2025
Question and Answer

What do we need to do with mail that is returned to the Bank?

By | December 18, 2025
Question and Answer

We have a customer who had a $5,000 unsecured Line of Credit with us. The customer repeatedly overdraws the Line of Credit, but at this time, there is an outstanding balance of $3,000. During a review of the account, the Lending Staff want to reduce the available credit on the unsecured Line of Credit to $3,000. Is an adverse action notice required?

By | December 17, 2025
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Has your institution updated its BSA/AML/OFAC policies and procedures to remove outdated FinCEN and OFAC references?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

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