Most Popular Compliance Content
Substitute check disclosure
02/26/2017
Do we give a substitute check disclosure at new accounts?
Who is an "insider"?
02/26/2017
Who is an "insider" for purposes of Regulation O?
Paper loan documents and audit bottlenecks
02/26/2017
Why do paper documents slow down the audit preparation process?
Reg E doesn’t say so, but
02/26/2017
Regulation E’s “Procedures for Resolving Errors,” along with that section’s Commentary, neither addresses nor prohibits banks from requiring helpful documentation such as police reports or signed and notarized affidavits. Are such actions are OK?
Fee that's POCL: Disclose on Loan Estimate?
02/26/2017
If a fee is POCL, the borrower was never intended to pay for the fee, should the fee be disclosed on the Loan Estimate? If we disclose these and the fees change (appraisal fee or credit report fee) and we adjust the POCL then it appears we are violating the specific lender credit by changing it, usually lowering the POCL fee. Should this only be disclosed on the CLoD or not disclosed at all since the borrower is not required to pay the fee? What has confused me are these two articles/posts which make it appear if it is a POCL or lender paid fee then it does not have to be disclosed on the LE. https://www.bankersonline.com/qa/lender-credits-loan-estimate#.V_fS_nldqlc.email https://www.bankersonline.com/qa/new-loan-estimateclosing-disclosures#.V_fS0lp1YlY.email