05/15/2006
We are planning a two-sided direct mail postcard. The copy on one side simply states “Living the American Dream.” The flip side lists several of our mortgage products (first time homebuyer, fixed and adjustable rate mortgages, and land and construction loans) as part of the copy. Does it matter which side we place the Equal Housing Lender and Member FDIC logos?
02/06/2006
Is it enough to have a cover letter showing the date prepared on the initial disclosures when we mail them to the customer? I have many loan files with initial disclosures which are unsigned. How do you know that the customer ever received them?
01/30/2006
If a customer requests not to receive a monthly statement because he/she is able to view the information from our online banking system, is there a compliance issue, keeping in mind that we will still generate the DDA/Sav statement monthly and send it to our cold storage system?
01/16/2006
I've been constantly running into a "You are not in compliance" issue in the company where I started working recently. Let's say I sent the application package to my client dated 12/01/2004. The client send the signed and dated package back one month later. My processor is insisting that the client should've dated it within 3 days. Otherwise, it's not in compliance. I think it does not make sense. If I send the package by regular mail it can take 5 days to deliver it, not to mention that the client may not sign it right away, and then it will take another 5 days to get the package. Please explain this 3 days compliance thing. I don't think my processor is interpreting it correctly.
08/29/2005
For initial disclosure purposes on a retail loan, we usually take phone apps. We obtain the borrower's signed credit authorization and then once credit is pulled we call the borrower and finish filling out the application. I have always been told that we need to send out our initial disclosures within three days of either the credit report or the signed application, whichever came first. I am now being told I am out of compliance because I disclosed too early. Please let me know what is the rule?
07/01/2005
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
The question was previously asked "Does a Good Faith Estimate need to be provided if a loan is closed within 3 days of application?" Guru David Dickinson replied "Yes. There is no exemption from the GFE requirement if the loan closed early." Our Compliance Officer states this is not accurate; if closed or denied within 3 days no GFE needs to be given.Who is correct?
05/01/2005
I received a press release the other day that said that because banks face increased government regulation, more hiring is needed to keep up with the workload.
02/21/2005
Is the bank allowed to withdraw and mail required minimum IRA distributions to customers if the customrs have not come to the bank to make the distribution election?