RSK.IQ.Staff, Author at RSK Compliance Solutions LLC • Page 43 of 122

RSK.IQ Question of the Week 6/11/18

Posted on June 11, 2018June 11, 2018 by RSK.IQ.Staff

Beneficial Ownership Rule and Estate Accounts

Issue/Inquiry

A New Jersey bank asks whether estate accounts are subject to the Beneficial Ownership Rule.

RSK.IQ Question of the Week 6/4/18

Posted on June 4, 2018June 4, 2018 by RSK.IQ.Staff

Regulation O and the Director as Registered Agent

Issue/Inquiry

The Bank, which is chartered in New Jersey, is making a commercial loan to a limited liability company. When it obtained the company’s Certificate of Formation, it noticed that one of its own directors is listed as “Registered Agent.” The director does not have an ownership interest in the company. Would the requirements of Regulation O be applicable to the loan because the director is the registered agent of the company?

RSK.IQ Question of the Week 5/29/18

Posted on May 29, 2018May 25, 2018 by RSK.IQ.Staff

CRA Public File and HMDA Disclosure Statement

Issue/Inquiry

The Bank will be having a FDIC Compliance and CRA review. In the CRA Public File, is it required to include a notice that the HMDA Disclosure Statement may be obtained on the CFPB’s Website? The Bank currently has the HMDA disclosure statements from the FFIEC for the previous two calendar years in the file.