CRCM Dates Flashcards
What is Reg Z open end non CC change in term notices? Error to credit deadline? Both non RE and HELOC
non RE: 45 day before effective date (provided=in mail, not when received) , if error- credit w/in 5 bus days: HELOC: 15 day before, if credit reduced or no more extensions- 3 bus days after action taken
What is loan threshold for BSA 5 yr records?
> =$10k excluding secured by real property
What is age requirement for MLA covered borrowers?
dependents <21, dependents 21+ if reliant for half of support, <23 if college
What is rate limitation time frame for mortgage SCRA?
1 year after end of active duty
What are Reg CC case by case hold rules?
can hold max 2 bus days if make $200 avail next bus day (once per cust per day). funds avail NLT 9am next bus day or when teller facilities avail for withdrawal
What is a Reg O principal shareholder?
> =10% voting shares and related interests
What is Reg E error resolution notice disc req & investigation timeline?
long form annually or short form w/ each statement; 10 bus days to investigate, 20 bus days if new acct, 45 days to investigate if provisional credit given w/in 10 bus days & notice w/in 2 days of credit (90 days if out of state, new acct, resulted from POS).
If unaffiliated pmt card networks merge, how long to add new card network to offering?
6 months
What is MSB threshold?
> $1k/trans/day/category
What is record retention of RFPA?
No time limit
How long is GLBA opt out good for?
Until customer revokes
How long does CRA have to block identity theft info?
4 business days if consumer gave proof of ID, info to be blocked identified, theft report provided and statement that transactions aren’t theirs
What are Reg O principal shareholder lending limits?
board approval if they own >=10% voting shares
What is Flood force place insurance requirement?
notify borrower w/in 45 days, 30 days to refund unearned premium. change in servicer identity provided w/in 60 days of effective date
What is SAR threshold & deadline to file?
> =$5k with known suspect= 30 cal days to file
=25k without known suspect = 60 days to file
insider = any amount
What is IRS withholding of US sourced income paid to foreign customers unless exempted?
30%
What is RESPA insurance requirement?
force place if >30 days overdue, 45 day disc before charge, 30 days after 1st notice, 2nd notice 15 days before charge. if annual notice: 45 bus day before, remove/refund w/in 15 days.
What is Reg O record retention?
Maintain records of all credit extended to insiders or related interests; 2 years minimum for EO/PS debt (3 yrs best practice)
What is change in terms notice Reg E, Reg, CC, Reg DD?
Reg E: 21 days before; Reg CC/DD: 30 days
What is QM qualification?
<=30 yr term, DTI <=43%, points/fees <=3% total loan where loan less than $105,158
What is large bank under CRA?
> 1.284b in prior 2 CYs
What is Reg M coverage?
lease for consumer purpose 4 months (OE or CE)
How many acct # digits can be on an electronic receipt under FCRA?
5 numbers
What is Reg CC cut off time?
no earlier than 2pm (or noon for ATM taking deposits)
What is Reg Z finance charge tolerance for non RE, RE & rescindable?
$5 if $1k; $100 if CE or secured by RE; $25 if rescindable
What is Reg E customer responsibility without losing access device?
$50 if notice w/in 2 bus days of learning of loss or w/in 60 days of statement w/ error. bank can require written notice w/in 10 bus days to grant prov credit.
When does W9 TIN cert expire?
Never
When should AANs be sent?
before or w/in 30 days after notifying CRA of negative info
What is Reg DD decimal place req for APY?
2 decimal places
What is timing for corrected TRID LE?
NLT 3 bus days within receipt of info requiring revision and 4 bus days before consummation
What are Reg W secured percentages?
100% sec by US gov’t obligations, 110% state gov’t, 120% other debt (corp debt/loans), 130% other (stock, non loans)
What is IRS withholding when docs can’t be collected or are invalid?
28%
When should CTRs be filed?
15 days after transaction, 25 if electronic
What is Reg DD periodic statement requirement?
no quarterly req but if sent must contain amount of interest, APY
What is Reg D withdrawal limit?
Can’t withdrawal >6x/month from savings or MMA
What is monetary instrument record threshold?
> =$3k
How often verify eligibility for CTR exemptions?
annually
How long after finding APR/ pmt error does FI have to correct?
60 days
What is the creditor threshold for exclusion from TRID?
<5 mortgages a year
What is TCPA length of a call?
can’t hang up <15 seconds or 4 rings
what are sunshine act agreements?
pmt to affiliate or NGEP >$10k or loan >$50k
What is Reg U coverage?
borrowers whose loans >$100k secured by margin stock require statement of purpose (based on loan amt not stock value)
When annual report for OFAC?
Submitted 9/30 with data as of 6/30
What is acceptable abandoned call rate?
<=3% are abandoned meaning not connect to live operator in 2 seconds, measured over 30 days
What is Reg E periodic statement timing?
mandatory monthly if EFTs, quarterly if no EFTs
What is eviction protection for rent in SCRA?
$3300
What is community development loan in CRA?
based on primary purpose (CRA uses revenue, HMDA uses income) <=$1mm
What is garnishment acct review period?
2 bus days to review if funds should be protected looking at each acct
What is Reg O control and presumed control?
Control: >=25% election/majority of board; presumed control: active as EO or director with >=10%
What is Flood definition of improved structure?
structure >50% above ground
How long is military fraud alert displayed & how long exempt from pre screens?
displayed at least 1 year, will not offer another credit report, excl from pre screenings for 2 years
How long to incorporate Junk Fax opt out requests?
30 days
What is Reg II record retention?
5 years
How long must FI honor internal TCPA DNC list?
5 years
How long to solicit public opinion in CRA strategic plan, how long is plan effective?
30 days; plan in effect for >1yr but <5 yrs, can bail out at 2 years
What is Reg DD record retention?
2 years
What is Reg Z LO compensation record retention?
3 yrs after payment or consummation (ATR, QM calc)
When is SCRA HUD 1 notice sent?
Sent once in default 45 days
What is a Reg M renegotiation?
lease renegotiated or extended by >6 mos = new lease
What is RESPA home counseling process?
Provide recent (<30 days) list of 10 counselors w/in 3 bus days of completed app
What is Reg W bank and single affiliate limit?
<=10% capital & surplus; <=20% aggregate all affiliates
When determine MLA status?
at obligation initiation or 30 days before
What is Reg Z closed end unit thresholds?
<=2 loan to consumer so bus purpose if 3; <4 consumer improvement to property so bus purpose if 5
How often register MSBs?
Every 2 years
What is RESPA request for info?
respond w/in 5 bus days. if requesting info on owner of mtg: 10 bus days. if on mtg bus: 30 days
What is a Reg E pre auth transfer?
in advance + regular intervals +same payor + at least every 60 days
What is expired info prohibited from a credit report?
info > 7 yrs old, bankruptcies >10 years old,
When does furnisher notify consumer that negative info was reported to CRA?
within 30 days after notifying CRA
What are financial disclosure reqs?
annual report as of 12/31 produced to those requesting by 3/31, to public 4/15
What is Reg E foreign remit rule for cancellation?
received within 30 minutes after pmt made, refund w/in 3 bus days of receiving request
How long is initial fraud alert displayed & how many extra credit reports does consumer get?
90 days, 1 add’l credit report/12 months
What is notice period for business w/ gross rev >$1mm?
reasonable period of time, 60 days of denial if cust requests notice
What is TCPA record retention?
24 months from when record produced/sale
What is reporting deadlines for IRS?
1/31 to customer, 2/28 to IRS paper, 3/31 IRS electronic
How long is extended fraud alert displayed & how many extra credit reports does consumer get?
requires ID authentication & proof of theft: 7 years, get 2 add’l free so 1/quarter initial year
What is a reg z small creditor?
=1 rural mtg
What is Reg Z closed or open transaction threshold?
57,200; mortgage no cap
How long escrow HPML if 1st lien?
5 years
What is NDIP high net worth customer threshold?
> =$5m excl residence & liabilities
What is max loan value of Reg U?
50% so $50k (aggregated for each customer)