Most Popular Lending Content
UDAP vs. UDAAP
05/12/2024
Where does the CFPB’s authority come in when they determine something is “Abusive”?
I think our CD Special is disclosing an inaccurate APY. It is less than the interest rate!
05/12/2024
My bank is doing CD specials a lot lately, and with rates being higher, there are now actual differences between the interest rate and the APY. I want to get it right! I’m concerned that something is wrong with our 13 month CD special (interest paid at maturity), because the APY is LESS than the interest rate. How can this be?!
Late Fees and Insiders
05/05/2024
Overdrafts may be one issue, but what about a late fee waiver on a loan for bank director - would this be a violation of Reg. O?
Appraisals, Values and Exceptions
05/05/2024
Assume the following terms on a loan to an individual to purchase real estate: The purchase price is $100,000. The borrower wants to add an additional tract of land in lieu of paying any cash down. The land is owned free and clear and is valued at $30,000. This results in a loan amount of $100,000 with total collateral value of $130,000 and a loan to value (LTV) of 77%. Am I right in thinking that I will have a loan to cost exception and not an LTV exception? This loan would not need to be reported against the banks 30% of capital limit on commercial real estate exceptions.
Compliance Management: How often should I test APYs and APRs?
05/05/2024
How often should compliance be testing APY and APR accuracy? I rely on our expensive software to get it right. Is that OK?