RSK.IQ Archives • Page 57 of 122 • RSK Compliance Solutions LLC

RSK.IQ Question of the Week 8/21/17

Posted on August 21, 2017September 26, 2017 by RSK.IQ.Staff

HMDA Reporting and the Re-Application

Issue/Inquiry

The Bank closed an application file for incompleteness when the applicant failed to meet all the closing conditions. Subsequently, the applicant re-applied for the loan, as required by the Bank when a commitment expires and all the conditions had not been met. The loan was then made after all the closing conditions were fulfilled. How should this be reported on the HMDA LAR?

RSK.IQ Question of the Week 8/14/17

Posted on August 14, 2017September 26, 2017 by RSK.IQ.Staff

Regulation O and a Loan to a Director’s Spouse

Issue/Inquiry

The Bank made a loan to the spouse of a member of the Bank’s Board of Directors. The director is not a co-borrower and the income of the director was not used in the underwriting for the approval process. Is this loan subject to Regulation O?

RSK.IQ Question of the Week 8/7/17

Posted on August 7, 2017September 26, 2017 by RSK.IQ.Staff

Regulation E and the Sole Proprietor

Issue/Inquiry

The Bank has a sole proprietor as a deposit account customer who may have suffered a fraudulent EFT on the account. Is a sole proprietor covered under Regulation E? Does the Bank have to give provisional credit, as required by the regulation?