New Account Check Holds When Adding an Additional Depositor to an Existing Checking Account
Question: Regarding Reg CC and check holds, can we apply a new account exception hold on an established account when a new account holder is added? Answer: Interestingly enough, yes. Here is the commentary from 12 CFR 229.13(a) (1)(b)(vi): If two customers that each have an established individual account with the bank open a joint […]
Is Compliance Ready for AI?
Is anyone else fascinating by ChatGPT and other natural language AI chatbot’s? Maybe you’re wondering if this new piece of technology can help you with your job as a compliance professional. Maybe you’re worried that AI technology will make compliance professionals obsolete. I wanted to see what ChatGPT could do if it replaced me at the […]
Dwelling Secured Loans Without Land
Question: Our member is purchasing a mobile home as a primary dwelling with 30% down making our loan amount $40,000. There is no land involved, just a lot space rent each month. Are we required to use consumer loan documents or mortgage loan documents? What regulations apply? Are we required to ATR this baby? By […]
HMDA again?
Q. Heather, I’ve heard some noise about HMDA (the Home Mortgage Disclosure Act, Regulation C). What are the changes? How can I tell if my credit union has to report HMDA data? A. Great Questions! Oh boy! Yes, there has been some movement with HMDA in the past few weeks. The Consumer Financial Protection Bureau […]
HMDA Reporting with Multiple Properties
Q. Heather, I have a HMDA (Home Mortgage Disclosure Act) Question. What if we have a member that is using a residential investment property for collateral to buy another residential investment property. Since the funds were used for a residential purchase would we need to report it for HMDA? A. Really great question. For business […]
Threats to fee income continue
Threats to fee income continue During the last few months, we have noted growing pressure on financial institutions from multiple fronts to regulate, reduce or eliminate fee income generated from overdrafts and non-sufficient funds (NSF) fees. The emerging threat to non-interest income was a roundtable discussion topic at our 2022 Executive Summit in May. Regulatory […]
Risk Based Pricing Notices on Business Purpose Loans
Risk Based Pricing Notices on Business Purpose Loans Question: Are risk-based pricing notices (RBPN) required on business purpose loans? Answer: No. RBPN’s are on required “in connection with an application for, or a grant, extension, or other provision of, credit to a consumer that is primarily for personal, family, or household purposes.” More info at: https://www.consumerfinance.gov/rules-policy/regulations/1022/70/ Back […]
Providing Mortgage Disclosures on a Denial
Providing Mortgage Disclosures on a Denial Q. Good morning Heather, I feel like this is a silly question – but I want to clarify it. If we receive a mortgage application with the six pieces of information from a borrower that constitutes an application under Reg Z and triggers the need to send a Loan Estimate – if […]
Lending to Minors
Lending to minors Q. Can we do loans for people under 18? I have never heard of it but apparently the credit union has made loans for members under 18 in the past. A. Great Question! There are no prohibitions regarding making a loan to a minor, however, in Utah the contract will be unenforceable until the […]
