10/18/2010
Under the extended FDIC TLGP program, are IOLTA accounts restricted to an interest rate of twenty-five basis points or less? These accounts are addressed separately from other NOW accounts in all the material I have received.
10/11/2010
With regard to Reg DD, if I change an account term which previously earned interest on any amount to a minimum balance requirement of a determined amount to collect interest, does this require thirty day disclosure or does the variable rate disclosure handed out initially cover the change?
07/19/2010
Our bank is planning to advertise a tiered-rate savings account. We want to make sure we disclose the APY correctly in the ad, but our rate structure is a little different from anything I've seen before, so I need a little help. We'll pay an interest rate of 0.50% on the portion of an account's balance from $0 through $5,000; plus 2.00% on the portion of the balance from $5,000.01 through $50,000; plus 0.10% on balances above $50,000 (all rates are variable, and these rates are what we would currently use). I seem to remember something from an old compliance training class about APY ranges. Is that the direction I should be headed?
06/28/2010
Community Bank does a consumer loan that is secured by a CD, but not 100% secured. Maturity dates for both loan and CD are consistent. The loan interest rates on CD backed loans are usually 1% over the interest rate being paid on the CD. Can the bank still charge this interest rate if loan is not 100% CD secured?
06/07/2010
Is it legal to pay to only a few customers a higher interest rate than disclosed and paid to other customers? I would think TISA would not allow this, but I can't find anything specific in the statute. We want to do this so as to not lose a large account.
04/05/2010
We are thinking about offering a "bump-up" rate CD product. If we do, I know we need to include in the original TISA disclosure the terms of and conditions of the product to the customer, but at the time the customer exercises his right to "bump" the interest rate on the CD, do we need to provide him/her with a new TISA disclosure reflecting the new rate/APY or does the original TISA disclosure suffice, even though the rate/APY will not be the same?
03/22/2010
Do we redisclose the truth in lending if the locked interest rate is lower than the rate used for the initial disclosure at application? Do we redisclose the truth in lending when going from a "to be determined" property to an actual property?
09/07/2009
Our bank routinely pulls credit bureau reports for all new loan requests. Although credit scores are only one of the criteria used to make a decision on a loan request, a poor score would weigh heavily on a credit decision. With regard to the FACTA provision of providing Credit Score Disclosures to residential mortgage loan applicants, a question arises about those applicants whose credit bureau we request and the report is returned without a credit score. The lack of a score is sometimes a factor in determining the decisioning of an application, the need for a co-signer, or even the interest rate that may be charged. Should a customer with a credit bureau history, but no score, be supplied with the notice?
06/16/2008
We currently send out full new account disclosures with our certificate of deposit maturity notices. Is this required? If not, is a disclosure required at any point during the renewal process or are we just required to disclose changes in the term?
04/28/2008
During a recent audit it was noted that for CD rate oral inquiries some staff members were disclosing the interest rate before the annual percentage yield. I can't find anywhere in Reg DD that says you must quote the APY first. Is there something I am missing?