07/30/2012
At the time of an application the rate was 3.79% and was displayed as such on all required disclosures. We are portfolio lenders so when our rates went down a little to 3.75% I gave the new rate to the customer but did not redisclose anything because we were still within the tolerances. Our compliance officer disagrees with me and thinks that I am required to redisclose. What is your opinion?
07/23/2012
The purpose of the loan is to provide funds to place a down payment on a primary residence. The collateral is a second on a residential property that they rent out. They plan to sell their current primary residence. Term is a 36/180 balloon. Do early disclosures apply?
07/16/2012
We (local bank) are doing a construction loan for a customer who already owns the land.Normally RESPA would not apply, however, we have also approved to handle the permanent financing in-house upon completion. Do we provide RESPA early disclosures for the construction loan only at this time, and new earlies when we refinance to the perm loan; Or, do we provide two sets of earlies now, one for the construction loan, and one for the future perm loan?
07/16/2012
I cannot find the record of retention for ATM/Debit Card applications or alterations in the state of MI. How long must they be kept?
07/02/2012
At what point in time is an account considered "opened" for Reg DD purposes? When the consumer sits down at the desk and begins the process? When the Signature card is signed? When the first deposit is made? Currently, we provide the disclosures as part of the opening process, but not at the beginning of the process.
07/02/2012
We are changing our debit cards from Visa to MasterCard. Do we need to send a new EFT disclosure?
06/25/2012
What is the effect of using an old form of Truth in Lending Disclosure Statement in a mortgage loan?
06/18/2012
Do overdraft lines have to have a quarterly disclose sent to each person on the program and eligible?
06/04/2012
A Bank holds mortgage on a primary residence and wishes to extend the maturity date. No other terms are affected, no new money, just extend re-payment. Can we do a note renewal without re-disclosing?
05/14/2012
My question pertains to the FDPA (Flood Disaster Protection Act) regarding the notification requirements to the borrower when a loan is modified. Is the bank required to provide the Notice of Special Flood Hazard and Availability of Federal Disaster Relief Assistance to the borrower when the loan is being modified? The modification was to lower the current rate on the existing loan. I have read the FDIC section 339.9 requirements, the 2009 Interagency Q and A's, and the Mandatory Purchase of Flood Insurance Guidelines (2007) and all are mute to the notice requirements pertaining to loan modifications.