10/08/2007
When a CD is renewed for the same term, interest frequency and interest payment method and only the interest rate is changing, are we required to send a separate disclosure that includes all of this information? Since the only change is the interest rate is that all the information we have to provide?
09/17/2007
Currently we mail out a CD maturity notice about a month prior to the maturity date. Once the certificate matures (we have automatic renewal) after the grace period of 10 days, we mail out a renewal notice. If we include the interest rate on the renewal notice, can we also include the APY and are there any specific requirements regarding this? I have read Reg DD and can't seem to understand its specific application to this situation.
07/02/2007
Are loans for small farms on which the borrower also maintains a primary residence considered agricultural loans or home loans subject to TIL (Reg Z) and if they are on less than 25 acres, RESPA? For instance, if a borrower with his residence and a walnut orchard on 30 acres applies for a refinance of his residence and orchard with an adjustable rate loan, would the loan require early ARM disclosures, interest rate disclosures and the right to rescind? Would the loan be exempt from Reg Z because of the agricultural nature of the property? In the same instance, if the property was 24 acres, would the loan also be exempt from the requirements of RESPA due to the agricultural nature of the property?
05/14/2007
Our department recently attended a web seminar about HMDA and we had a recent issue that created a question. We had a loan that was a three month bridge loan of a RE property and it was not reported as HMDA because of it being short term and refinancing into permanent. It is now being refinanced for another term of three months with a higher interest rate. Does it now become HMDA reportable because it is refinanced, or not because it is still short term?
03/05/2007
On an ARM loan, a rider is attached to the mortgage and both are recorded. Is it a requirement to disclose the interest rate on the rider? I can't locate any Reg stating the rate must be or does not have to be disclosed on rider. What Reg can you refer me to?
01/29/2007
We have a large LLC Customer who has a Now account. It was supposed to be changed when noticed at our last Compliance exam. I hate to bother this very large account, with a low interest rate and move him into a higher rate Money Market Account. What are the options and penalties?
11/27/2006
What is the minimum number of days you must charge on a CD penalty?
10/09/2006
What are the bank policies that need board approval and how frequently?
10/09/2006
I'm looking for someone who remembers when MMDAs and NOW Accounts were legalized for banks. Seems like MMDAs were first, the fall of some year, then NOW Accounts were authorized at 5.5% for commercial banks on January 5th of the next year. Was that 1980-1981? I'm trying to educate some younger bankers on Reg D and the history of reserves, NOW Accounts, etc.
07/10/2006
Do you have to state the interest rate and APY on a monthly bank statement for interest-bearing accounts?