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Rich Moldenhauer
Flagship Bank Minnesota

 
 
Loan Escrow Account Policy
Contributed by:VP‚ Compliance/BSA/Legal
Asset size: Bank with over $1b
Location: Northeast
Description: The bank will comply with all provisions of the Real Estate Settlement Procedures Act (RESPA). If an escrow is established on a RESPA covered loan, the escrow amounts shall be calculated in accordance with the requirements of the regulation, and appropriate initial and annual disclosures shall be provided to the borrower. If the institution transfers or acquires the servicing of any RESPA covered loan, the bank will make a timely, accurate servicing transfer disclosure to the borrower.

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MORE PEER CONTRIBUTED DOCUMENTS:

948 Documents 56 Answers 41 Exam Watches 45 Vendor Reviews

Loan Policy
Asset size: with under $250m
Description: Extensive bank loan policy for real estate mortgage loans, commercial & agricultural loans and installment loans. Very in-depth RE loan procedures. Sections include details for loan category policy guidelines, catagory & LTV limits, non-desirable loans, payment procedures, collection procedures, environmental policy. loan review for all categories, loan review process, internal risk rating process, officer lending authorities, bank board review and requirements. Includes Exhibits for various lending categories and allowance for loan losses.
Identity Theft Prevention Program
Asset size: with between $500m - $1b
Description: Identity Theft Red Flag Policy with sample letter and Red Flag worksheet; 16 pages.
Loan Policy
Asset size: with between $250m - $500m
Description: This Loan Policy is 45 pages long. It was written by our Senior Lender with over 30 years of experience. This has been approved by the OCC and includes agricultural lending guidelines as well.


RELATED QUESTIONS AND ANSWERS:
Q
Escrow requirements short term real estate loan
Asked by: VP,‚ Audit
Asset size: Bank with
Location:AL

Is escrow required on a short term real estate loan? We have a primary residence- real estate secured- loan where the balloon pmt is maturing. We want to extend the balloon for 90 days. We are not currently escrowing for T&I- Loan was closed prior to escrow requirement. No fees are being charged for the extension- No new money exchanged- Do we need to escrow?
A
Answered by:VP, ‚ Lending/Credit/Loan Admin
Asset size: Bank with between $250m - $500m
Location: IL

Be careful if your loan is a high cost loan. If the rate triggers the loan as a high co...
Q
Initial Escrow Account Statement - Payment amounts
Asked by: Audit
Asset size: Bank with
Location:AR

We recently closed a loan that required an escrow account. For whatever reason, a tax payment did not fall within the initial escrow computation year, so the only disbursement indicated was for insurance. However, the escrow payments were determined using both the insurance amount and the tax amount from the previous year. Is this permissible under the reg, or does this count as pre-accrual? Any help is appreciated. Thanks!
A
Answered by:AVP, ‚ Lending/Credit/Loan Admin
Asset size: Bank with over $1b
Location: CA

This is acceptable. At the time of closing the balance for the escrow account is based u...


RELATED EXAM EXPERIENCES:
FDIC - Compliance | May 2011
exam experience posted by a Manager‚ Back Office/Deposit Operations from member with under $250m in assets
None
FRB - Compliance | June 2013
exam experience posted by a Compliance/BSA/Legal from member with under $250m in assets
Focused more on escrows and letters sent out to customers than expected.
State Regulatory - S&S | October 2013
exam experience posted by a CEO‚ CEO from member with under $250m in assets
BASEL III

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Mimics Inc

 
 

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