We have an applicant who has applied for a consumer purpose loan - consolidate personal credit card debt. The applicant's mother is going to pledge commercial real estate as collateral for the loan. Do we need to prepare an LE / CD?
Hello, does anyone have a whisleblower procedure and policy they would be willing to share? Thank you!
Here's a tool I've been working on for a while as I wanted to comnie my indivodual worksheets into one master. I am able to provide 7 areas for internal testing on lending - Reg B, Reg V, Flood, Fair Lending, Regs G & Z for MLO.testing, Military Lending Act and one for some california specific requirements. These are intended to hold the data to back up your narrative for the actual monitoring report, which I have posted here prior and will update as needed. The protections are on just to maintain the formulas, and the intent is to leverage what you are testing fro use in multiple areas. You enter your loan specific infromation on the master page, and the infromation flows through to the other worksheet to reduce workload in moniotring by topic / regulation. Not all fields are carried over, mostly as a space saver, but not all fields matter in each review. You can easily turn off the protections (not password protected), and use as normal if you prefer. I have about 8 more topics to put into this format, and then will do my operational testing sheets in another manner, if it works in this universal format. Internal testing is a huge cornerstone of your compliance program, and this method has aided me in recalling problematic areas quickly. Examiners have been very pleased. Hope this will be beneficial to you in your on-going compliance journey!!
Do you allow minor account holders to have debit cards? If so, do you have the parents sign a parental consent? What does the parental consent include?
Does anyone use a daily compliance blog source? Do you think the services are worth the price paid? I would like an objective opinion on this issue.
What is the procedure for other banks in closing CD accounts? Do you allow customers to close per phone call or email or do you require the customer to come into the bank? Or do you accept a "letter of instruction"?
Can you give a copy of a credit report you pulled to the customer if they are asking for a copy?
Anyone have a Deposit Reconcilation Policy - Practices ??
Does anyone have a Suspicious Activity Report that staff is to complete when any SAR activity has occurred? This form is completed and then forwarded to the BSA Officer. Thanks!
I'm looking for sample lease agreements or additional disclosures for self-service safe deposit boxes, along with any procedure recommendations from other banks that offer these. Thank you!