RSK.IQ.Staff, Author at RSK Compliance Solutions LLC • Page 31 of 122

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”?

RSK.IQ Question of the Week 2/4/19

Posted on February 4, 2019February 1, 2019 by RSK.IQ.Staff

RESPA and Establishment of an Escrow Account for an Existing Loan

Issue/Inquiry

The Bank does not escrow for real estate taxes on construction loans since the borrower pays the taxes directly to the municipality. Would there be any disclosures needed or issues if the Bank requires the borrower to escrow for real estate taxes as part of a modification of the construction loan to an amortizing schedule of payments?