05/23/2005
I'm confused regarding FACT Act Section 212c Disclosure of Credit Scores by a Lender. Volume 8, Number 15 of ComplianceAction indicated that lenders must disclose credit scores for any closed-end loan or HELOC for consumer purpose. Loans for a business purpose would not need the disclosure sent. Based on the above, we would not send a disclosure to the individual who applies for a loan to purchase a 1-4 family investment property. The loan is for business purposes and the borrower signs a document stating that. However, at a recent tele-conference, I was told that we should still send the disclosure because a consumer report was pulled and it's a 1-4 family. What are your thoughts?
05/23/2005
Could you please tell me the criteria for the estimated truth in lending and good faith estimate and when it is required and when it is not?
05/23/2005
With an emailed application that has been faxed in by the borrower, what are the compliance guidelines for the GFE and TIL?
11/01/2004
We are an FDIC regulated bank and are considering starting to offer HELOCs. What are the required disclosures and are there good "cheat sheets" you could recommend? I am fairly new to compliance and would appreciate some help in understanding this product.
10/01/2004
In Advisory Letter 2004-10, the Comptroller of the Currency advises national banks on credit card marketing and account management practices that may be unfair or deceptive.
10/01/2004
Question: We have a customer who wants a home equity line of credit that will be used to purchase a new home. The line will be secured by the home being purchased.
07/01/2004
As required by the FACT Act, the Federal Reserve Board has initiated action to conduct a study on how the credit and insurance prescreening and solicitation system affects consumers.
03/01/2004
03/01/2004
02/02/2004
Can a home equity line of credit be set up contractually to also be used as overdraft protection (i.e., an automatic sweep from the line to cover any overdraft that may occur in the customer's checking account)?