09/19/2011
I am working on a refinance of a primary residence and the loan is being increased from $105,000 to $108,000. Is this a changed circumstance? What disclosures do I prepare? Also, the attorney is now charging me for a re-draw fee. Can I pass that on to the customer?
09/05/2011
We have a mortgage loan that was originally done as a temporary finance. The customer decided to sell the property instead. He has one deferral to extend the loan 6 months to allow time to sell. We were wondering if we did another deferral, if it would still be temp financing, and exempt from HPML?
08/22/2011
My borrower is using another person's home as collateral on her loan. The person putting up the collateral is not on the loan. Who signs the disclosures (good faith, tila, etc)? Is it the borrower or the person putting up the collateral or both?
08/15/2011
Our bank wants to establish an employee loan program where we offer a 2% discount off of our normal customer rates. Outside of Reg O, are there any regs that I need to consider as we put this together?
08/15/2011
According to the Reg B ECOA proposal, does the adverse action notice pertain to deposit accounts if they use a credit report/scores to open an account?
08/08/2011
Where can I find the new model availability policy disclosures (appendix C) for Reg. CC?
08/01/2011
We want to start offering OD LOCs to our customers on automatic approval based on the customers QualiFile score with ChexSystems. We do not want the customers to have to apply for this, but rather, offer them the product after we have run them through ChexSystems and determined that they are qualified. What type of disclosures do we need for this? Do we need to have wording on the checking account application stating that we will use the ChexSystems report for this? Do you have any examples that you can give me?
07/25/2011
Our software only supports 2 of the 3 required disclosures for private education loans. They claim that if you approve the loan within 3 days of receiving the application, that you are not required to give the customer the "application" disclosure, only the approval and final disclosures. Is this true or do I need to find the other disclosure somewhere else?
07/25/2011
With the new $200 rule for Reg CC, since our Bank has a next-day availability policy, our general policy is not affected. But on the case-by-case holds, if I understand it correctly, we will now have to make the first $200 available on the next business day. If I am right up to this point, do we need to send out a change-of-terms notice to our customers about the change for the case-by-case holds only?
07/25/2011
We have an owner who will not be signing the note and just the mortgage. Should they sign the TIL along with the Right of Rescission?