08/01/2022 We have a loan secured by a dwelling where the borrower used the funds to purchase a house and he is making improvements on it. The payments are interest only for 12 months. After the 12 months, he is getting a permanent takeout loan to replace it. Would this be a HMDA reportable loan or does the fact that it is short-term financing take precedence over the purchase and home improvements? |
07/18/2022 For a TRID construction loan disclosed as two transactions, what should we disclose as the interest rate if it’s variable we don’t know what the rate will be during the permanent phase? |
06/06/2022 We have an instance where a customer is wanting to open a benefit account for a fellow church member whose wife has recently become ill. His initial intention was to set the account up under his name and tax ID information and he would direct the funds to the individuals. However, our institution does not typically open these types of accounts and we're hoping for recommendations and/or what is consistent in the banking industry for these types of benefit accounts. |
05/17/2022 Q. If the bank agrees to make an interim construction loan but the borrower has a takeout letter from another institution, is the bank required to send a permanent loan disclosure for informational purposes? |
04/28/2022 The person convinced the customer to allow remote sign into the customer’s computer to “stop the hacking process.” In this process, the customer provided both of his debit card numbers and PINs. |
04/20/2022 We have a designated disaster area close by and were wondering which activities in these areas would qualify for CRA Community Development? |
04/04/2022 How often does a Bank have to update its BSA risk assessment? |