Most Popular Compliance Content
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
How to Make Sure Reg E Forms Are Compliant
02/26/2017
Where can I see if the Reg E forms that we are using are compliant? The forms we have look as if someone put it on our letter head and I want to be certain that it has all the information needed.
RFPA Disclosure & Verification of Deposit (Reg P)
02/19/2017
I am currently working on an audit for the RFPA. We have several verification of deposit that come into our bank from state and local government agencies. For example, the local housing authority sends requests pertaining to the Federal Assisted Housing Program. Should we treat these requests as if they came from a federal agency and should they contain the RFPA disclosure?
Reg B Appraisal Notices & Commercial Loans: Lien
02/19/2017
In regards to Reg B appraisal notices and commercial loans: does the loan need to be secured by a first lien on a dwelling for the notice requirements to apply or is it any dwelling secured loan - regardless of lien position? For example, an LLC is securing a commercial loan with a 2nd lien on a dwelling, do they get the appraisal notice or not?
Gift cards and the Prepaid Rule
02/19/2017
Does the new prepaid rule affect gift cards?