RSK.IQ.Staff, Author at RSK Compliance Solutions LLC • Page 21 of 122

RSK.IQ Question of the Week 9/16/19

Posted on September 16, 2019September 16, 2019 by RSK.IQ.Staff

New Debit Card “Bonus”

Issue/Inquiry

The Bank is looking to launch a campaign to increase point-of-sale (“POS”) transactions. The target audience will be low volume debit card holders, and they will receive a statement credit to their checking account if they increase the number of POS transactions to 15 or more. Is the Bank required to provide new disclosures? Are there any other requirements the Bank would be responsible for?

RSK.IQ Question of the Week 9/9/19

Posted on September 9, 2019September 9, 2019 by RSK.IQ.Staff

Purchasing Loans and Loan Participations

Issue/Inquiry

The Bank does not engage in one-to-four family residential lending. It is considering purchasing loans or loan participations in such loans from another financial institution, which will service the loans. As a prerequisite to the purchase, the Bank would underwrite the purchase of the loan or loan participation as though it were originating the loan. If the Bank does not offer or engage in residential lending, does that preclude it from purchasing loans or loan participations in such loans originated by another bank, which will service the loans?

RSK.IQ Question of the Week 9/3/19

Posted on September 3, 2019September 3, 2019 by RSK.IQ.Staff

Insurance Policies That Do Not Meet the Private Flood Insurance Definition According to the Flood Rules

Issue/Inquiry

The Bank has accepted a private flood insurance policy for the past three years that does not meet the definition of a private flood insurance policy according to the current Flood Rules. Would this policy be “grandfathered in,” or must the Bank force-place flood insurance?