Question of the Week

  • QUESTION: Under Regulation B must a co-applicant receive an adverse action notice?

    ANSWER: Regulation B only requires notification of the primary applicant where one is readily apparent.  As a practical matter, some loan documentation systems are set up to generate notices for all applicants.  While prudent and conservative, the regulation would not mandate such activity.

    Reference: 1002.9(f).  Note: It is important to note that the Fair Credit Reporting Act requirements mandate certain disclosures to all applicants. Please review the Fair Credit Reporting Act for more information. 


Question of the Week Archive

  • QUESTION: For a condominium, what is the flood insurance coverage amount?

  • QUESTION: May a consumer be held liable for unauthorized EFTs made with an access device?

  • QUESTION: Is a bank required to verify the natural person(s) indicated as the “beneficial owners” of the legal entity’s account are in fact the beneficial owners?

  • QUESTION: Is a bank required to continue sending its annual privacy notice as required under current Regulation P?

  • QUESTION: Regarding flood insurance and NFIP reauthorizations, should community banks make plans now for how to handle a lapse in NFIP coverage if it happens in late 2017?

  • QUESTION: What must the bank do to comply with the beneficial ownership rules in the scenario below?

  • QUESTION: If a HMDA-reportable application is received in the calendar year 2017 but the loan does not close until 2018, which data points are reporting banks required to collect and report?

  • QUESTION: Is a HMDA reporting bank required to obtain a Legal Entity Identifier (LEI) or can it use its RSSID #?

  • QUESTION: Is a bank required to follow the amendments to the mortgage disclosure requirements (TRID) on October 1, 2017?

  • QUESTION: When does a bank need to provide the ARM Notice of Change?

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