03/12/2012
We typically provide an updated TIL any time a revised GFE is provided, even if the TIL revised disclosure threshold is not triggered. We do this from a customer service standpoint. So let's say a change in circumstance happens, so we send an "updated" TIL along with the GFE (note that the APR revised disclosure threshold was less than .125%). Later another change in circumstance happens after this one which affects the APR. Which APR do we use in checking the APR accuracy, the initial APR or the "updated" APR? Note again that the "updated" TIL was not required to be sent but it was sent anyway from a customer service standpoint.
03/12/2012
In talking with The Federal Reserve Board, it was determined that a negative finance charge is not a charge but a credit and should not be used in calculating the APR. We have found a blog on <a href="http://www.bankersonline.com/lending/guru2010/gurus_ldng102510a.html">BankersOnline website</a> that states differently. Where can we find the information to back up the answer that was given on this blog?
03/05/2012
We are changing the term from fixed rate to variable rate on a work-out consumer term loan secured by their residence which is a manufactured home on leased land. We prepared change in terms documents consisting of Promissory Note and Disclosure document. The document states "disclosures about the variable rate feature have been provided to me earlier." (actually they were not). Are any other disclosures required?
02/13/2012
Are there any restrictions on providing eStatements and no paper statements for checking/savings accounts (even at customer request)?
01/30/2012
On a consumer purpose loan secured by the borrowers' home, is it required to give a co-signer (not an owner of the home) the Servicing Disclosure, and the Credit Score Disclosure?
01/23/2012
Related to the Reg B ECOA changes to adverse action notices. If using a consumer reporting agency like ChexSystems that also gives you a score and uses credit information, should you be disclosing their score and range of scores and listing the items that adversely effected their score on the notice when denying a deposit account?
01/16/2012
We have several accounts that are set up to receive their Checking Account Statement (Paper) Annually. Are we out of compliance by not sending them a statement monthly when our disclosures state that they have 30 days from the date the statement was made available to us to notify us of any errors?
01/09/2012
With the new RESPA, how are renewals to be treated? Do we need to give all the disclosures and waiting periods? If we need to give early disclosure, when are they to be dated? What about the final disclosures?
12/05/2011
If you are making a loan to pay off a student loan, would the new student loan disclosures be applicable?
11/28/2011
The commentary to Reg B and Reg V recognizes that the definition includes the phrase “arranges a loan” but also points out that in requiring credit score disclosures, section 1100F of the Dodd-Frank Act does not state that the credit score disclosures are only required for adverse action decisions related to credit. My question - we use eFunds/QualiFile which interfaces with TransUnion for both Debit and Credit information that translate to a score for opening DDA and SAV accounts. Are we now required to disclose in the same manner for denied DDA and SAV account opening requests?