Vendor Guru Q&A - Compliance

Latest Compliance - Reg. Z Topics

Impact of fee disclosures on HMDA reporting

03/13/2016

The changes to HMDA are not effective until January 1, 2018, so what is the fee concern related to HMDA at this time?

Difference between preapproval and prequalification

02/28/2016

The CFPB recently posted an update to what the difference is between a preapproval and a prequalification. Has there been a change in regulation that minimizes Preapprovals?

New TRID disclosures- Reg Z

02/27/2016

Does a loan to a consumer to purchase vacant land for investment fall under needing the new TRID disclosures?

Increasing an Existing Construction Loan

02/21/2016

Does increasing the amount of an existing consumer construction loan without extending the maturity date trigger TRID?

Timing of Initial Rate and Payment Change: ARM

01/31/2016

I have an ARM servicing question. Does the timing of the initial rate and payment change need to be stated in the Note?

Fee for Future Mortgage Releases-County Clerk

01/31/2016

Our bank collects a fee for future mortgage releases. Even though at closing the fee goes to us, eventually it is paid to the county clerk when we release the mortgage. For the purpose of the Loan Estimate and the Closing Disclosure is this fee considered paid to the Lender or to the County Clerk? Either way it would still be a 10% Tolerance category correct? If it is paid to the lender would that mean it needs to be included in the finance charge that affects the APR for calculating HOEPA?

Credit Sales and Integrated Disclosures

01/03/2016

Prior to Integrated Disclosures, a credit sale (selling and financing an OREO property) required us to disclose the Total Sale Price on an Estimated and Final TIL (12 CFR 1026.18(j)). Is there a similar requirement on the new Loan Estimate and/or Closing Disclosure or has this gone by the wayside?

Transfer CC Payment from Closed Acct. to Active

01/03/2016

Our bank collections dept is being asked to transfer credit card payments from a closed acct to an active acct. OCC. is our regulator. What fed guidelines & internal controls would we violate?

Condo Questionnaire Fee- New TRID Rule

12/27/2015

Under the new TRID rule, where would a Condo Questionnaire Fee be disclosed on the Loan Estimate? The questionnaire is required for the transaction but some condos may or may not charge such fee.

TRID's Services 10% Cumulative Tolerance

12/20/2015

In regards to TRID's services that a consumer is permitted to shop for, if the customer does not select a service provider and requests that the lender choose a service provider for them, is the amount charged subject to the 10% cumulative tolerance?

Recalling Bank Transfers

12/17/2023

How do we recall a bank-to-bank transfer that was unauthorized? We are the ODFI.

Must we provide online deposit account opening disclosures on our website?

12/17/2023

We allow customers to open deposit accounts online. We’d prefer to keep disclosures (especially our rate and fee sheets) off our website, so that the competition can’t see them. Must we provide TISA disclosures up front, or can we mail them later? I seem to remember Reg DD allows us to send disclosures up to 10 days later when the customer isn’t at the bank.

Delayed Large Item Hold

12/10/2023

It was discovered two days after initial deposit date that a teller did not place a large item exception hold requested by the branch manager. Can we place a hold for the dollar amount that would have been held for 7 days from the date of deposit and mail the customer the form using large item exception hold and note the reason for the delay on the hold notice? What is a best practice for this type of situation?

EHL Logo Use on the WWW

12/10/2023

Is the term “Equal Housing Lender” on our website sufficient or should we actually have the “Dog House” logo?

Must we send periodic deposit account statements?

12/10/2023

Must banks send a periodic statement on deposit accounts?

Latest Compliance - Reg. Z Topics

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