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: When is an anti-steering disclosure required?
A: The anti-steering disclosure is not required by regulation to be provided to a customer. The disclosure is provided as a safe harbor to protect the bank from claims that the consumer was steered to a product. It may be required by investor or internal policy. Click here for a template for the anti-steering disclosure.
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 Home Mortgage Disclosure Act specifies when a loan should be reported as a cash-out refinancing rather than a refinancing?
- If the bank considers the transaction to be a cash-out when processing the application or setting the terms under investor or bank guidelines, the bank will report the loan as a cash-out refinancing.
- If there is no distinction made between a cash-out refinancing or refinancing, the bank sets the terms without regard to the amount of cash received by the borrower and the loan is not made using investor guidelines, the bank will report the loan as a refinancing.
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.