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Identifying Higher Risk Customers using Keyword Searches
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CFPB’s UDAAP Is Seriously Looking for Illegal Discrimination Practices
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What Does Your Institution Need to Know About Evolving Russian Sanctions?
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Deposit Insurance Changes for Trusts and Mortgage Servicing Accounts
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We are originating a HELOC loan to fully pay off an existing HELOC loan. Since there is no new money involved, would Right of Rescission apply?
Answer: Since the property is being deeded over to the borrower, the borrower is essentially purchasing the property for what is remaining Yes. Although no new money is being advanced, this is a new HELOC that will allow a customer to redraw on funds from the line once the loan is paid down. The Right …
If the financial institution has a customer with a virtual currency kiosk located on their premises, (i.e. inside the gas station or convenience store), do we need to treat them as a Money Service Business (MSB)?
Answer: Since the property is being deeded over to the borrower, the borrower is essentially purchasing the property for what is remaining Yes. Although no new money is being advanced, this is a new HELOC that will allow a customer to redraw on funds from the line It depends. If your customer is simply leasing …
