Is the bank required to provide an appraisal notice when it takes real estate as an abundance of caution?
If a loan is secured by a dwelling, the appraisal notice is required. If the dwelling is an abundance of caution, an appraisal itself, however, would not be required. Abundance of caution specifically exempts the lender from hanging to get an appraisal, as long as it is a true abundance of caution. The bank should not invoke this exemption if its credit analysis reveals that the transaction would not be adequately secured by sources of repayment other than the real estate, even if the contributory value of the real estate collateral is low relative to the entire collateral pool and other repayment sources.
See Appendix A in the Interagency Appraisal and Evaluation Guidelines here: https://www.fdic.gov/regulations/laws/rules/5000-4800.html
I have a question in regards to the matricula consular identification. This is a form of ID given by the Mexican government. Is this form of ID acceptable for CIP purposes in opening a new account?
The CIP rule neither endorses nor prohibits bank acceptance of information from Matricula IDs. Instead, a bank must decide for itself, based upon appropriate risk factors, whether the information presented by a customer is reliable. The CIP rules simply permit use of "any other government-issued document evidencing nationality or residence and bearing a photograph or similar safeguard." https://www.ffiec.gov/bsa_aml_infobase/pages_manual/olm_011.htm
However, some banks refuse to accept this form of ID, because they believe it's too hard to verify the legitimacy of these cards. If your bank decides to accept this form of ID, you may still want a secondary source of ID if you have reason to doubt the authenticity of the card.
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