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.

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Compliance Corner Archives

2024 Mar Compliance Corner

Posted on 3/26/2024
When is an Anti-Steering Disclosure required? Did you know that HMDA specifies when a loan should be reported as a cash-out refinancing rather than a refinancing?

2024 Feb Compliance Corner

Posted on 2/26/2024
Does MLA apply to the purchase of vacant land? Did you know that the bank should have a callback policy in place for wire request that are received electronically?

2024 Jan Compliance Corner

Posted on 1/25/2024
Is 12 months the maximum that we can spread an escrow shortage out over? Did you know that there is an exception to alphabetical order listings on the Loan Estimate?

2023 Dec Compliance Corner

Posted on 12/15/2023
Is an opt-out option required for fraud alert calls and texts? Do you know the types of transactions that are considered Electronic Funds Transfers?

2023 Nov Compliance Corner

Posted on 11/16/2023
What should you be considering regarding the FDIC recently proposed rules that would remove restrictions on hiring candidates with criminal histories? Do you know the most common cybersecurity-related threats for banks?

2023 Oct Compliance Corner

Posted on 10/26/2023
If you have a loan that was locked at 7.25% and disclosed on the LE at 7.25% but mistakenly changed to 7% on the Initial CD and then corrected on the Final CD back to 7.25%, does the bank need to honor the 7% or can the loan close with 7.25%?

2023 Sept Compliance Corner

Posted on 9/28/2023
Wondering if you can issue an access device off of a HELOC? Did you know that it is a best practice for all Mortgage Loan Originators to have their NMLS ID Number on their business cards and email signatures?

2023 Aug Compliance Corner

Posted on 8/29/2023
Check out the recent Compliance Alliance question of the week and Review Alliance Did You Know fact.

2023 July Compliance Corner

Posted on 7/26/2023
Check out the recent Compliance Alliance question of the week and Review Alliance Did You Know fact.

2023 June Compliance Corner

Posted on 6/28/2023
Check out the recent Compliance Alliance questions of the week and Review Alliance Did You Know facts.

2023 May Compliance Corner

Posted on 5/25/2023
Check out the recent Compliance Alliance questions of the week and Review Alliance Did You Know facts.

2023 Apr Compliance Corner

Posted on 4/17/2023
Check out the recent Compliance Alliance questions of the week and Review Alliance Did You Know facts.

2023 Mar Compliance Corner

Posted on 3/26/2023
Check out the recent Compliance Alliance questions of the week and Review Alliance Did You Know facts.

2023 Jan Compliance Corner

Posted on 1/25/2023
Check out the recent Compliance Alliance questions of the week and Review Alliance Did You Know facts.

2022 Dec Compliance Corner

Posted on 12/13/2022
Check out the recent Compliance Alliance questions of the week and Review Alliance Did You Know facts.

2022 Nov Compliance Corner

Posted on 11/16/2022
Check out the recent Compliance Alliance questions of the week and Review Alliance Did You Know facts.

2022 Sept Compliance Corner

Posted on 9/27/2022
Check out the recent Compliance Alliance questions of the week and Review Alliance Did You Know facts.

2022 Aug Compliance Corner

Posted on 8/18/2022
Check out the recent Compliance Alliance questions of the week and Review Alliance Did You Know facts.

2022 July Compliance Corner

Posted on 7/26/2022
Check out the recent Compliance Alliance question of the week and Review Alliance Did You Know fact.

2022 June Compliance Corner

Posted on 6/23/2022
Check out recent Compliance Alliance questions of the week and Review Alliance Did You Know facts.

2022 May Compliance Corner

Posted on 5/25/2022
Check out recent Compliance Alliance questions of the week and Review Alliance Did You Know facts.

2022 Apr Compliance Corner

Posted on 4/22/2022
Check out recent Compliance Alliance questions of the week and Review Alliance Did You Know facts.