09/03/2017
We are going to open a loan production office and need guidance on what types of signs need to be in the lobby. I'm thinking only the Equal Housing Lender Poster, but not sure. We are not taking deposits, and we are not a HMDA reporter.
01/29/2017
In my search for guidance on e-Sign compliance for delivery of appraisals (Reg B) and Closing Disclosures (Reg Z) there seems to be a difference in what is recommended for Reg B & Reg Z. All the guidance on delivery of the closing disclosure states that a read or delivery receipt is not a recommended method of documenting proof of the date delivery occurred. However, guidance on Reg B delivery date of the appraisal tends to lean the other way and regarding a read/delivery receipt. In fact the commentary
1002.14(a)(4)(I) even states ... “Delivery occurs three business days after mailing or delivering copies... or when evidence indicates actual receipt by the applicant, whichever is earlier". With the commentary in mind is it necessary for us to get a confirmation e-mail to document the actual date of delivery of the appraisal or can we simply apply the guidance from the commentary and rest on the delivery occurred three business days after xmailing whether snail or electronic mail?
01/22/2017
I have been instructed to lead a project around compliance ramifications if negative interest rates were to occur in the US. With regard to deposit accounts, would all TISA and other initial disclosures need to be updated to reflect this change. Since the change in terms would negatively affect our customers. This would be quite an undertaking as we have 10 member banks. Would all of our advertisements have to be re-disclosed? Any feedback is greatly appreciated.
11/20/2016
Are state-specific disclosures (such as home equity or ARM, etc.) specific to the borrower's residence state or the state of the originating bank is? If a borrower crosses a state line to use a branch nearer their home or a borrower is buying a vacation home in another state and goes to a bank in that state, which state applies to the disclosures?
07/31/2016
Is a Notice Regarding Overdraft Fees disclosure required to be posted on an ATM? A question was recently asked about required ATM signage (https://www.bankersonline.com/qa/required-signage-atm) however I did not see mention of this Notice. Could this be a CA specific notice or one that may have been required in the past? The notice reads “If you do not have sufficient funds in your account for the withdrawal amount requested,completing the transaction may result in overdraft fees if you have given us prior permission to complete such transaction….”
07/10/2016
What is the TRID owner’s and lender’s title insurance calculation?
06/19/2016
What does “didn’t shop” mean in relation to Section B on page 2 of the Closing Disclosure?
06/12/2016
What does “did shop” mean in relation to section C on page 2 of the Closing Disclosure?
06/05/2016
Can seller-related information be omitted from sections M and N on page 3 of the borrower’s Closing Disclosure?
01/31/2016
Our Retail Division is getting very creative in coming up with fees that we have not charged in the past. I understand that dormant/inactivity fees are defined at the State level and are allowed on accounts advertised as "free." Would the same hold true for debit card inactivity and/or online banking inactivity fees? Would these fees be allowed on "free" accounts if properly disclosed? I have the same question for return mail fees.