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The loan is not a designated loan, it is not secured by a building or a mobile home, therefore the flood regulations do not apply to the transaction.
Section 1026.38(h)(3) states that general lender credit should be disclosed on the appropriate line in Section J of the Closing Disclosure. There are no instructions to show part of the credit as a principal reduction.
The lender’s credit can be revised in certain situations (Section 1026.19(e)(iv)(D), such as when the rate was not locked at the time the loan estimate was provided, but then is later locked.
Usually record retention is listed on OFI website in each state. Most states require signature cards for 7 years so that is usually what IRAs go with since it has a product with it. But again it varies in each state.
There is a general rule in BSA for five years. In the back of the FFIEC exam manual there is a list if more specific record retention rules that is helpful.
Same thing with escheatment…some states escheat and some dont.
For more information on how to access this 2-hour webinar recording visit: https://mycomplianceresource.com/event-registration/?ee=495. If you have questions you want our presenters (Jack Holzknecht, Deborah Crawford, and Matt Stone) to answer during the recording then please submit them by January 4th. The recording will be emailed to all registrants the week of January 11th.
You will need to comply with your current disclosures as they have provided greater protection than the rules require. I also recommend that you review your agreements annually to ensure the intent of your action is accurate based on the regulatory requirements.
Response provided by: Terri Sands.
Eric did an hour long Q&A session on this topic that you can find here: https://mycomplianceresource.com/product/pandemic-relief-managing-compliance-issues-webinar-recording-2/.
Response from one CMG member about how their bank is trying to keep their employees safe during the Covid_19 outbreak:
“We have been divided into two teams at each location. The teams include members from across bank departments—bookkeeping, operations, new accounts, loan support staff, loan officers and compliance. We are working on a rotating M-W-F and T-T schedule. All drive-thrus are open. The lobby is open by appointment only and we are asking if the customer feels well or has been exposed prior to allowing them to come in. The rationale is if someone tests positive, only one team would be asked to stay in isolation and the bank could continue to operate. Everyone is pitching in and doing things they don’t normally do and we are all cleaning at the end of each day so the next group comes in to a clean environment. Only time will tell if this works.”
I will post a link to your question on our social media pages to see if anyone is having problems.
Thanks,
Amy FaustDirector of Marketing
Compliance Resource, LLCI was staying in a hotel for a soccer tournament many years ago, and a bride hung her wedding dress on a sprinkler head in her room. It caused the fire alarms in the whole hotel to go off, all rooms were evacuated, numerous rooms were flooded, and the poor bride had to deal with the humiliation of everyone figuring out what she had done. I don’t think I ever found out if the ordeal happened before or after her wedding ceremony.
Congratulations Melinda! Jack can certainly tell you what a blessing being a grandparent is. Enjoy this special time with your family!
Great! We look forward to seeing you all at the conference. We plan on getting together at some point so we will send you an email once we have our plans.
Both of those are great picks! Melinda- Jack and I saw Medal Count yesterday practicing at the track, and he’s a beautiful horse!
Jack and I are watching the Olympics right now, and we’re wondering if the FSB just wants us to think it’s a hoax. 😉
I read an article about his murder too. That’s horrible!
For anyone interested in the medal count as of 5:00pm EST on 2/11/14 here it is:
1.) Norway- 11 medals (4 gold, 3 silver, 4 bronze)
2.) Canada- 9 medals (4 gold, 3 silver, 2 bronze)
3.) Germany- 5 medals (4 gold, 1 silver)
4.) Netherlands- 8 medals (3 gold, 2 silver, 1 bronze)
5.) USA- 7 medals (2 gold, 1 silver, 4 bronze)
