Bankers Alliance Compliance Corner
Editor's Note: The following was submitted by Bankers Alliance. LBA, through its subsidiary Louisiana Bankers Service Corporation, has partnered with Bankers Alliance to give banks access to three compliance-related programs. Click here for more information.
Q: Does MLA apply to the purchase of vacant land?
A: Generally, yes, the Military Lending Act would apply as vacant land loans are not specifically exempt. Note, however, that transactions to finance initial construction of a dwelling that will secure the loan would be exempt as a residential mortgage, so in some cases this exemption may apply: “…Exceptions. Notwithstanding paragraph (f)(1) of this section, consumer credit does not mean: A residential mortgage, which is any credit transaction secured by an interest in a dwelling, including a transaction to finance the purchase or initial construction of the dwelling, any refinance transaction, home equity loan or line of credit, or reverse mortgage…” Click here to view the regulation.
Compliance Alliance offers a comprehensive suite of compliance management solutions. To learn how to put them to work for your bank, call (888) 353-3933 or email info@compliancealliance.com and ask for the membership team.
Did you know that the bank should have a callback policy in place for wire request that are received electronically?
- A callback process helps verify a customer’s identity before sending funds.
- Always call the customer using the telephone number in the bank’s system and never rely on contact information contained in the electronic request.
- Proper documentation of the call including time and date, telephone number and person spoken to help create a record of due diligence for the bank.
Review Alliance is an independent group of compliance specialists offering banks deep-dive audits of their existing transactions, recommendations about program enhancements or guidance on future safety and soundness. Virtual Compliance Officer was added in 2020—a new shared service-model using bank-dedicated compliance officers; perfect for monitoring and guiding your bank remotely. To learn how to put them to work for your bank, call (833)-683-0701or email info@bankersalliance.org and ask for the membership team.