February 2019 • RSK Compliance Solutions LLC

RSK.IQ Question of the Week 2/25/19

Posted on February 25, 2019February 22, 2019 by RSK.IQ.Staff

RESPA, Section 8, and Permissible Compensation

Issue/Inquiry

During a recent compliance examination, the Bank was asked whether the mortgage broker who brought the initial application to the Bank had performed the “five things” required in order to receive compensation in conjunction with the transaction. What is this a reference to?

RSK.IQ Question of the Week 2/19/19

Posted on February 19, 2019February 15, 2019 by RSK.IQ.Staff

Beneficial Ownership and Court Appointed Receiver

Issue/Inquiry

Would the beneficial ownership and CIP requirements apply in the case of an existing business account that is taken over by a court ordered receivership? In this case, the court has ordered an accounting firm act as receiver. The Bank is requesting identification on the signer and the firm. The Bank would also like the firm to complete a beneficial ownership certification. Are these requirements applicable?

RSK.IQ Question of the Week 2/11/19

Posted on February 11, 2019February 8, 2019 by RSK.IQ.Staff

HMDA and Preapprovals

Issue/Inquiry

The CFPB HMDA data collection chart indicates that the financial institution must determine whether the transaction involved a preapproval request for a home purchase loan under a preapproval program. What is considered a “preapproval program”?