RSK.IQ Archives • Page 50 of 122 • RSK Compliance Solutions LLC

RSK.IQ Question of the Week 1/16/18

Posted on January 16, 2018January 16, 2018 by RSK.IQ.Staff

CIP and Photo ID

Issue/Inquiry

The Bank’s CIP requires a photo ID to be obtained from the borrower in order to verify the borrower’s identity. Such identification discloses the borrower’s race and gender. When can a photo ID be obtained, in order to avoid the appearance of using such information in violation of Regulation B’s prohibition against discrimination?

RSK.IQ Question of the Week 1/8/18

Posted on January 8, 2018January 7, 2018 by RSK.IQ.Staff

HMDA HELOC Thresholds

Issue/Inquiry

If the Bank did not originate more than 500 HELOCs in the past two years, is it still responsible for collecting the GMI/HMDA information under the new rules? If it anticipates originating more than 500 HELOCs in 2018, does it need to collect the new HMDA data fields?

RSK.IQ Question of the Week 1/2/18

Posted on January 2, 2018December 29, 2017 by RSK.IQ.Staff

New HMDA Rules and Reporting Total Loan Costs and Fees

Issue/Inquiry

When are total costs and total loan costs and fees reportable under the new HMDA reporting rules going into effect on January 1, 2018?