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Loan Secured By A Dwelling

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?

TRID Construction Loan Disclosed as Two Transactions

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?

Opening A Benefit Account

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.

Sending Permanent Loan Disclosure for Informational Purposes

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?

Liability for customer information being obtained through fraudulent call made to customer

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.

Designated disaster area close by qualification for CRA Community Development

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?

BSA Risk Assessment

04/04/2022
How often does a Bank have to update its BSA risk assessment?