RSK.IQ.Staff, Author at RSK Compliance Solutions LLC • Page 37 of 122

RSK.IQ Question of the Week 10/15/18

Posted on October 15, 2018 by RSK.IQ.Staff

Regulation DD and Change of Name of Deposit Account Product

Issue/Inquiry

The Bank is converting many of its deposit products from one product to another. A Change in Terms letter will be mailed regarding five such product changes. For two products, the only change to the customer is the name of the product. These are noninterest-bearing accounts with no service charges and no minimum balance requirements. Is the Bank is required to send a 30-day advance notice to these customers?

RSK.IQ. Question of the Week 10/8/18

Posted on October 8, 2018October 5, 2018 by RSK.IQ.Staff

HMDA Partial Exemption and Information Collected Prior to its Effective Date

Issue/Inquiry

For HMDA reporting, does the Bank need to report all fields, including the fields that were exempted on May 24^th for loans that were acted upon prior to when the exemption was granted?

RSK.IQ Question of the Week 10/1/18

Posted on October 1, 2018September 28, 2018 by RSK.IQ.Staff

RESPA and Establishing an Escrow Account for an Existing Loan

Issue/Inquiry

Customers have contacted the Bank regarding their residential mortgage, which closed last year. They are requesting that the Bank begin escrowing for their taxes. Prior to January of 2018, the Bank was not escrowing for taxes. Are there any regulatory implications or requirements if it was to begin escrowing for this customers taxes at this time?