CRCM Dates Flashcards
1
Q
What is Reg Z open end non CC change in term notices? Error to credit deadline? Both non RE and HELOC
A
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
2
Q
What is loan threshold for BSA 5 yr records?
A
> =$10k excluding secured by real property
3
Q
What is age requirement for MLA covered borrowers?
A
dependents <21, dependents 21+ if reliant for half of support, <23 if college
4
Q
What is rate limitation time frame for mortgage SCRA?
A
1 year after end of active duty
5
Q
What are Reg CC case by case hold rules?
A
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
6
Q
What is a Reg O principal shareholder?
A
> =10% voting shares and related interests
7
Q
What is Reg E error resolution notice disc req & investigation timeline?
A
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).
8
Q
If unaffiliated pmt card networks merge, how long to add new card network to offering?
A
6 months
9
Q
What is MSB threshold?
A
> $1k/trans/day/category
10
Q
What is record retention of RFPA?
A
No time limit
11
Q
How long is GLBA opt out good for?
A
Until customer revokes
12
Q
How long does CRA have to block identity theft info?
A
4 business days if consumer gave proof of ID, info to be blocked identified, theft report provided and statement that transactions aren’t theirs
13
Q
What are Reg O principal shareholder lending limits?
A
board approval if they own >=10% voting shares
14
Q
What is Flood force place insurance requirement?
A
notify borrower w/in 45 days, 30 days to refund unearned premium. change in servicer identity provided w/in 60 days of effective date
15
Q
What is SAR threshold & deadline to file?
A
> =$5k with known suspect= 30 cal days to file
=25k without known suspect = 60 days to file
insider = any amount
16
Q
What is IRS withholding of US sourced income paid to foreign customers unless exempted?
A
30%
17
Q
What is RESPA insurance requirement?
A
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.
18
Q
What is Reg O record retention?
A
Maintain records of all credit extended to insiders or related interests; 2 years minimum for EO/PS debt (3 yrs best practice)
19
Q
What is change in terms notice Reg E, Reg, CC, Reg DD?
A
Reg E: 21 days before; Reg CC/DD: 30 days
20
Q
What is QM qualification?
A
<=30 yr term, DTI <=43%, points/fees <=3% total loan where loan less than $105,158
21
Q
What is large bank under CRA?
A
> 1.284b in prior 2 CYs
22
Q
What is Reg M coverage?
A
lease for consumer purpose 4 months (OE or CE)
23
Q
How many acct # digits can be on an electronic receipt under FCRA?
A
5 numbers
24
Q
What is Reg CC cut off time?
A
no earlier than 2pm (or noon for ATM taking deposits)
25
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
26
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.
27
When does W9 TIN cert expire?
Never
28
When should AANs be sent?
before or w/in 30 days after notifying CRA of negative info
29
What is Reg DD decimal place req for APY?
2 decimal places
30
What is timing for corrected TRID LE?
NLT 3 bus days within receipt of info requiring revision and 4 bus days before consummation
31
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)
32
What is IRS withholding when docs can't be collected or are invalid?
28%
33
When should CTRs be filed?
15 days after transaction, 25 if electronic
34
What is Reg DD periodic statement requirement?
no quarterly req but if sent must contain amount of interest, APY
35
What is Reg D withdrawal limit?
Can't withdrawal >6x/month from savings or MMA
36
What is monetary instrument record threshold?
>=$3k
37
How often verify eligibility for CTR exemptions?
annually
38
How long after finding APR/ pmt error does FI have to correct?
60 days
39
What is the creditor threshold for exclusion from TRID?
<5 mortgages a year
40
What is TCPA length of a call?
can't hang up <15 seconds or 4 rings
41
what are sunshine act agreements?
pmt to affiliate or NGEP >$10k or loan >$50k
42
What is Reg U coverage?
borrowers whose loans >$100k secured by margin stock require statement of purpose (based on loan amt not stock value)
43
When annual report for OFAC?
Submitted 9/30 with data as of 6/30
44
What is acceptable abandoned call rate?
<=3% are abandoned meaning not connect to live operator in 2 seconds, measured over 30 days
45
What is Reg E periodic statement timing?
mandatory monthly if EFTs, quarterly if no EFTs
46
What is eviction protection for rent in SCRA?
$3300
47
What is community development loan in CRA?
based on primary purpose (CRA uses revenue, HMDA uses income) <=$1mm
48
What is garnishment acct review period?
2 bus days to review if funds should be protected looking at each acct
49
What is Reg O control and presumed control?
Control: >=25% election/majority of board; presumed control: active as EO or director with >=10%
50
What is Flood definition of improved structure?
structure >50% above ground
51
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
52
How long to incorporate Junk Fax opt out requests?
30 days
53
What is Reg II record retention?
5 years
54
How long must FI honor internal TCPA DNC list?
5 years
55
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
56
What is Reg DD record retention?
2 years
57
What is Reg Z LO compensation record retention?
3 yrs after payment or consummation (ATR, QM calc)
58
When is SCRA HUD 1 notice sent?
Sent once in default 45 days
59
What is a Reg M renegotiation?
lease renegotiated or extended by >6 mos = new lease
60
What is RESPA home counseling process?
Provide recent (<30 days) list of 10 counselors w/in 3 bus days of completed app
61
What is Reg W bank and single affiliate limit?
<=10% capital & surplus; <=20% aggregate all affiliates
62
When determine MLA status?
at obligation initiation or 30 days before
63
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
64
How often register MSBs?
Every 2 years
65
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
66
What is a Reg E pre auth transfer?
in advance + regular intervals +same payor + at least every 60 days
67
What is expired info prohibited from a credit report?
info > 7 yrs old, bankruptcies >10 years old,
68
When does furnisher notify consumer that negative info was reported to CRA?
within 30 days after notifying CRA
69
What are financial disclosure reqs?
annual report as of 12/31 produced to those requesting by 3/31, to public 4/15
70
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
71
How long is initial fraud alert displayed & how many extra credit reports does consumer get?
90 days, 1 add'l credit report/12 months
72
What is notice period for business w/ gross rev >$1mm?
reasonable period of time, 60 days of denial if cust requests notice
73
What is TCPA record retention?
24 months from when record produced/sale
74
What is reporting deadlines for IRS?
1/31 to customer, 2/28 to IRS paper, 3/31 IRS electronic
75
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
76
What is a reg z small creditor?
=1 rural mtg
77
What is Reg Z closed or open transaction threshold?
57,200; mortgage no cap
78
How long escrow HPML if 1st lien?
5 years
79
What is NDIP high net worth customer threshold?
>=$5m excl residence & liabilities
80
What is max loan value of Reg U?
50% so $50k (aggregated for each customer)
81
Who must adhere to Interchange Fees Reg II?
bank and affiliate >$10b
82
What is HPML safe harbor?
APR <=1.5% APOR 1st lien; 2.5% first lien jumbo loan; 3.5% subord lien
83
What are appraisal thresholds?
>=$250k residential, >=$1mm commercial; loans
84
What is record retention for large business under ECOA?
60 days unless special then 12 mos
85
What is FDIC grace period when someone dies?
6 mos
86
What is Reg Z OE OD opt in consent time period?
reasonable opp to opt in (usually 30 days), revoke in writing, cant charge over limit fee in >3 billing cycles
87
When is escrow disclosure required under RESPA?
45 days of establishing acct or settlement
88
What is HPA good payment history?
borrower not 60 days PD in past 24 mos, not 30 days PD in last 12 months
89
How long is W8 BEN or W8 BENE valid?
For CY executed + 3 years
90
What is Lending Limits threshold?
15% capital/surplus for individual; all insiders as a group <100% c&s; if common enterprise: 50% c&s
91
Who is covered under Reg E foreign remit rules?
C2C, C2B, 100+ remittances in past 2 CYs
92
What is Flood def of small lender?
93
What is IRS reporting for 1099B?
Mailed 2/15 to customer
94
What are Reg O EO lending exclusions?
OD
95
What is CTR threshold?
>$10k
96
What is Flood borrower notice?
reasonable time period before closing (usually >=10 days)
97
What is info sharing opt out time under Reg P?
within 30 days of notice for FCRA-affiliates & Reg P non affiliates
98
When must furnish complete dispute investigation and notify consumer of results?
30 days, can be 45 if provided add'l info
99
What is record retention of Reg U?
3 yrs after loan satisfied
100
What is Internal Revenue Code for serving bank & customer?
Serve bank, serve customer w/in 3days of serving bank. customer has 20 days to begin civil suit to object so bank waits 23 days after being served before releasing record
101
What is de minimis for SAFE Act?
>5 applicants in rolling 12 months
102
What is Reg II reasonable fee?
21 cents (base) + 5 (bps) + 1 cent fraud prevention
103
When notify customers of increasing delays of shortening delays under Reg CC?
30 days before if neg, 30 days after if psoitive
104
What are extension of credit exemptions from Reg O?
salary advances <30 days, CC's <=$15k, OD<=$5k
105
What is Reg Z OE CC fee limit? Penalty fee max?
<25% credit limit in first year; $25
106
when is CHARM & ARM disclosure given?
at application or before paying non refundable fee, if by phone/broker then within 3 bus days
107
What is Reg E error resolution for foreign transmit rules?
if sender reports w/in 180 days, provider has 90 days to investigate, send results in 3 bus days, refund in 1 bus day
108
What are RESPA covered loans?
construction only, vacant land >25 acres, consumer purpose 1st lien res property principally for 1-4 fam occupancy (indv, dirt, dwelling)
109
What are acceptable telemarketing times?
8am-9pm
110
What is record retention for ECOA consumer records?
25 mos
111
What is Flood record retention?
life of loan, SFHDF form & receipt of notice for period of time bank owns loan
112
What is reasonable time under FCRA to allow opt out of affiliate marketing?
generally 30 days (like GLBA)
113
What are covered HOEPA loans?
>6.5% for 1st lien or >8.5% for sub lien OR loan pts/fees >5% where loan greater than $20 579 OR pp penalty >36 months
114
What are HPML appraisal reqs?
exception
115
What is ECOA appraisal notice time requirement?
provided within 3 bus days of taking application, copies given if 1st lien on dwelling
116
What is TCPA definition of EBR?
closed acct w/in last 18 months or customer inquiry in last 90 days
117
What is Reg Z open end non CC periodic statement req?
at least quarterly & each billing cycle w/ >$1 FC. mailed 21 days before (CC's) or 14 days (all other open end) from date delivered not due date or expiration of grace period
118
What is MLA national guard service requirement?
180 consecutive days full time
119
What is Reg CC non continental delay for deposits?
add one add'l day to limits
120
What is licensed appraiser definition?
performing on properties 1-4 families
121
What is CRA small business loan test?
based on loan size not business size, loan
122
What is Reg DD acct opening disc reqs?
give prior to acct or svc provided, if not present- mail NLT 10 bus days after acct opened
123
When must FI stop sending advertising per CANSPAM?
10 days
124
What is MLA active duty requirement?
>30 days
125
What is MLO registration time req?
30 days if info becomes inaccurate, 60 days if merger/acquisition
126
What are Reg O EO lending limits?
lesser of <2.5% capital or $100k; agg limit <=15% c&s, add'l 10% if amt over 15% is secured
127
What are Flood loan exceptions?
128
How long is FCRA opt out good for?
5 years
129
How long can a cust authorization be granted for under RFPA?
3 months
130
What is error resolution timeline if error & no error in Reg E?
if error occurred: correct in 1 bus day, notify in 3 bus day. if error didn't occur: honor items 5 bus days after notification
131
What is QM safe harbor?
APR <1.5% above APOR for 1st lien. APR <3.5% above APOR for jr lien
132
What is error resolution for Reg Z OE CCs?
billing error notice rec from cust w/in 60 days after 1st statement w/ error; w/in 30 days mail acknow of notice, correction or notice of no error. investigation complete w/in 2 billing cycles <90 days
133
What is CTR exemption phase 2?
5 transactions in 1 year >$10k + customer for 2 months
134
What is notice period for business w/ gross rev
at application or 30 days after completing
135
When to return premiums & funds for HPA?
all premiums returned w/in 45 days, insurance back to servicer w/in 30 days from servicer notification to cancel
136
What are single, join, rev thresholds under FDIC?
Single =$250k, joint=$500k, rev informal (ITF, ATF, POD) and formal(living/family trust)
137
What is RESPA servicing transfer requirement?
if CE 1st lien mortgage, notify w/in 3 bus days of app to unique addresses
138
Who is exempt from Reg Z OE repayment disclosures?
cardholders that have paid their acct in full for 2 consec months
139
What is record retention for small business records under ECOA?
12 mos
140
How often re file SAR for continuing activity?
every 90 days
141
What is RESPA servicing transfer notice req?
15 days before transfer from goodbye servicer, 15 days of effective date from hello servicer
142
What is RoR timing?
midnight at third BD after consummation, delivering 2 copies of RoR notice, or delivering CD
143
What is rate limitation time frame for non mortgage SCRA?
180 days after end of active duty
144
When is ATP (OE) or ATR (CE) performed?
at acct opening or increasing credit
145
What are Reg O director lending limits?
prior board approval for loans >5% capital or $500k
146
What is OFAC record retention?
5 years
147
What is Reg Z record retention?
2 years unless mortgage then 5 years
148
What banks are covered under HMDA?
>$44mm assets AND office in MSA; de minimis= 25 CE or 500 OE as of 12/31 prior 2 CYs
149
What is ATR record retention?
3 yrs for evidencing calculation
150
What is Reg E foreign remit rule threshold?
151
What is Reg E cust responsibility if lost access device?
if notice w/in 2 bus day and 60 days of transmittal: lesser of $50 or unauth transaction. notice w/in 2 bus day and after 60 days of transmittal: $500. no notice w/in 2 bus days and after 60 days transmittal: unlimited
152
How quickly provide copies of CRA report?
5 days
153
If true hit on OFAC, when report to Treasury?
10 days
154
When file exemption for listed entities for CTR phase 1 exemption?
within 30 days of exemptible transactions
155
What is 1099S amount for exceptions?
$250k single, $500k joint
156
What is Reg M record retention?
2 yrs after disclosures made
157
What is 1099R withholding?
10% federal, non IRAs 20%
158
What is Reg Z PEL acceptance period?
30 days w/ 3 bus day RoR
159
What is APR tolerance for regular loan (single advance) and irregular?
1/8 of 1% ; 1/4 of 1%
160
What is RESPA allowable secondary market payment threshold?
reasonable if take loan app and perform 5/14 compensable services
161
What is a Reg E new account?
any account is new for first 30 days
162
How often must Reg P annual notice be sent?
Rolling 12 months
163
What is HPA record retention?
2 years
164
What is time process for subpoena or formal written RFPA request?
Wait 10 days from service from agency or 14 days from mail before releasing record
165
What is resident alien in country exception to IRS withholding?
<180 days
166
What point font must SCRA waiver be?
12 point
167
What is Branch Closing timing requirement?
90 days to regulator, 90 days to customers, 30 days sign on door
168
What are Flood insurance requirements?
single fam residential=$250k, non res=$500k; res contents=$100k, non res contents =$500k; deductibles res=$10k, non res $50k, condo $25k
169
What is Reg Z OO duration time?
15+ days
170
What is surplus/deficiency/shortage escrow amount under RESPA?
surplus >50: refund w/in 30 days. surplus <50: refund or credit next year pmt. shortage <1 month: repay in 30 days. deficiency<1mo: require repayment in 30 days.
171
How long are 314b notices good for?
1 year
172
What is intermediate small bank under CRA?
>321mm but <1.284b in prior 2 CYs
173
What is small bank under CRA?
174
When is CRA data reporting due?
3/31, same as HMDA
175
What is TRID CD delivery?
3 bus days before consummation
176
When to make copies under Reg Z & M?
before closing, give to lessee
177
What is BSA record retention?
5 years
178
How does does a CRA have until notifying a consumer after receiving notice of ID theft?
30 days
179
When is ECOA AAN provided? What is counteroffer time period?
within 30 days after completed application, taking AA on incomplete app or AA on existing account. 90 days for applicant to accept counteroffer
180
What is garnishment lookback period?
2 months (not 60 days): protected amt is lesser of balance or pmts received
181
What is Reg CC ATM disclosure rule?
Must disclose if deposits not removed >2x/week
182
When is notification of breach required per HITECH?
60 days
183
How long for approved application in ECOA to be considered withdrawn?
30 days of no response (no AAN required)
184
What is a related interest under Reg O?
insider owns >=25% voting securities or controlling influence; or EO/D AND >=10% voting securities; or owns 10% + no one has greater percentage
185
What is Reg CC record retention?
2 years
186
What is COPPA record retention?
3 years
187
When disclose ATM fee in Reg E?
in advance on screen or paper, can term b/f fee assessed
188
What is RESPA error resolution notice?
acknowledged w/in 5 bus days of receipt, 7 bus days to investigate. 30 bus days to resolve (can add 15). FCRA uses cal days
189
What are limits for rate increase or expiration of promo rate for Reg Z OE CCs?
no increase in FC, rate, fee for 1st year; no increase in promo rate w/in 6 mos
190
What is HPA LTV requirement?
80% borrower can request cancellation, 78% mandatory, 77% high risk loans
191
What is Reg E record retention?
2 years
192
When does TRID LE get sent?
3 bus days after application, NLT 7 bus days before consummation/closing
193
What is RESPA loss mitigation?
contact borrower within 36th day of delivery, written notice NLT 45 days. if loss mit app received, acknowledge in writing in 5 bus days of receipt
194
What is timeline for Reg E stop pmts?
oral or written 3 bus days before scheduled trans date, bank can require written conf w/in 14 days if oral
195
What is garnishment record retention?
2 yrs from when FI receives order
196
What is CRA test percentage?
50% lending 25% investment 25% service
197
What is RESPA escrow opening & closing requirement?
12 mos w/ 2 mos escrow; annual analysis every 12 months; closing NLT 2 bus days before acct closed if cust requests, 30 bus days if other reason.
198
When must data furnisher notify consumer if dispute frivolous or irrelevant?
5 business days
199
What do changes to LE before & after consummation do to CD?
if before: 3 bus day waiting period. if after but <30 days: mail within 30 days. 60 days if non numerical clerical error. 60 days to refund overpayment
200
What is time process for search warrant under RFPA?
90 days after search warrant served
201
What are interstate branching rules for Loan to deposit ratios?
ratio in covered state > 50% ratio in host state
