Publications Archive

Question: We sent a notice of incompleteness to a customer and one of the items they need more time to get this info. It is permissible to provide another notice of incompleteness (“NOI”) to extend the current NOI deadline for a later date? Answer: ...Read More

Lawmakers met this week and reconvened the 2023 Regular Session. Below is a recap of the proceedings. Next week legislators will take spring break. Budgets Released Gov. Kay Ivey transmitted her budget proposals to the Legislature this week as the Regular Session reconvened after ...Read More

Q. Does RESPA require that we collect a cushion for escrow accounts? How large of a cushion must be collected? A. RESPA allows you to have up to 2 months’ cushion in an escrow account but doesn’t *require* that you have 2 months’ cushion. ...Read More

Question: Do Reg CC exception holds apply to check deposits drawn on foreign banks? Answer: If the check is actually drawn on a foreign bank not located in the US, it would not be considered a “check” covered by Reg. CC. Therefore, would not ...Read More

Q: Can a large deposit hold be placed on a next day item (cashier’s check) for the amount over $5,525? A: Yes, Reg CC allows this for cashier’s checks or treasury checks. Members commonly believe that they cannot place any exception hold on a ...Read More

Q: Do we have any TCPA issues making phone calls to current customers to sell them other bank products? A: Generally, if you have an established business relationship with the customer, there would be no compliance issues with TCPA to call them and sell ...Read More

Q:  If an individual named as a beneficial owner of a new legal entity account is an existing customer of the covered financial institution subject to the financial institution’s CIP, is the bank still required to identify and verify the identity of this individual ...Read More