Compliance Questions & Answers
Compliance touches every corner of community banking, from operations to customer interactions. Discover key areas like internal controls, policy development, and training programs that keep your bank aligned and accountable.
A disclosure delivered in an electronic format will not meet the requirement to provide disclosures in writing under a given regulation (e.g., Regulation Z or DD) unless it meets E-SIGN requirements specifically provided by the relevant regulation.
Reference: E-Sign Act Requirements, Fed. Consumer Affairs Update, Sept. 2014.
The Security Officer must report on the effectiveness of the Security Program annually and when updates are made to the program.
Reference: FED 12 CFR 208.61; OCC 12 CFR 21; FDIC 12 CFR 326
The financial institution may issue one notice with information related to multiple accounts of an account holder.
Reference: 31 CFR 212.7(g).
The requirement applies to any designated loan, including consumer and commercial loans where a building or mobile home and personal property secure the loan.
Residential Building Examples:
- Single family dwelling
- 204 family residential building
- Other residential building containing 5 or more residetnail units
- Mixed use building in which the total floor area devoted to nonresidential uses is less than 25% of the building's total floor area, this includes: condominium, apartment, hotels, motels, tourise homes, rooming houses where the normal occupancy is six months or more
Non-residential Building Examples:
- Commerical buildings
- Office or Retail Space
- Wholesale Space
- Hospitality Space
- Buildings where the normal stay is 6 months or less including condominiums, apartments, hotels, motels, tourise homes, rooming houses
- Houses of Worship
- Schools
- Recreational Buildings
Reference: 12 CFR 339.3; Interagency Flood Q&A 2022 Determining the Appropriate Amount of Flood Insurance Required; Amount 3 and 4.
No. Surplus provisions apply only if the borrower is current at the time of analysis. A borrower is considered current if their payment is less than 30 days past due.
Loan servicers may keep the surplus in the escrow account if the borrower is not current pursuant to the loan terms.
Reference: 12 CFR 1024.17(f)(2)(ii).
No. The exemption process is at the financial institution's discretion. This means, you may choose to forgo exempt designations and continue to report large currency transactions for every customer.
Reference: 31 CFR 1020.315(b).