06/09/2014
Does the homeownership counseling notice need to be provided on open-end home equity lines of credit? This is a RESPA requirement, and our HELOCs are not subject to RESPA.
06/09/2014
Regarding the new ECOA Valuation Rule that amends the appraisal provision of ECOA's Regulation B. Would it apply to home builders? I can't find anything in the regulation that it wouldn't.
05/19/2014
My bank never prepared early disclosures for a non-owner occupied home equity in the past. About a month ago someone said we should be making those disclosures, so we have started. My question is: Do we really have to send out early disclosures for a loan being backed by a non-owner occupied home?
05/19/2014
Is a new truth in-lending required when there is a change in circumstances? (2nd lien)
05/12/2014
When an advance is made on an overdraft line of protection is a notice (advance notice) required to be sent to the Borrower? If so, which regulation does this fall under?
04/28/2014
When the bank imposes 25% penalty rate for 60+ days past due credit card accounts, do they need to send 45-days advance notices to delinquent card holders before imposing penalty rate?
01/27/2014
Are non-bank lending institutions subject to interest rate disclosure regulations for business loans?
07/15/2013
When an originator takes a phone application, what is acceptable by the regulators that all the proper disclosures have been provided to applicant? My other concern is can we still pull a credit report with written authorization from applicant? ( This usually being provided by a signed application.) I was and still am under the impression that credit should not be pulled until you have an application.
07/08/2013
If a customer has 50% of their total sum in investment products and on occasion uses their NOW or DDA account for personal payments, would regulation DD apply? It is the banks policy not to open consumer accounts. We are Private Banking, and open accounts mainly for investment purposes but do offer for convenience,other types of bank accounts. For these instances we also require the customer to sign a certification letter that states that accounts are being maintained for facilitating the acquisition of investments and only incidentally personal, family or household purposes, which in no event will involve use of more than 50% of the account balance.
06/24/2013
My question is about the fee summary at the end of a checking statement. The Total for this period column would be for that specific statement cycle. The Total Year-to-Date column is where my question comes. Assuming that an account had NSF/OD from 12/18/12 thru 12/28/2012 and the statement cycle was 12/18/2012-1/17/2013. The first statement printed in 2013; the Total Year-to Date field should be zero, correct; however the Total for this Period would include the fees for the entire statement cycle. From a compliance perspective, the Total Year-to-Date column would be missing any fees that happened between 12/18/2012-12/31/2012 correct?