11/08/2015
What is a common tolerance for loan payoff refunds/waivers for overpayments and underpayments?
11/01/2015
Our bank originates indirect secured home improvement loans. Our rates change only once or twice a year and we automatically lock the rate as soon as the
application arrives (via fax or email).
We do not use signed rate lock agreements which has never been questioned during past exams, but is this practice acceptable under TRID? Must we have
a signed intent form?
Also, are we in compliance if we indicate the rate is locked on the initial Loan Estimate? (Hopefully we can avoid having to revise Loan Estimates by
locking at a later date).
10/26/2015
Where should I list a verification of employment fee?
10/18/2015
In training with our forms provider for the TILA RESPA Integrated Disclosures , it was mentioned that the late fee may not be applied until after 15 days. I have seen this nowhere else. Is there a reference so I can find this?
10/18/2015
We have a customer who is refinancing his primary residence to purchase a vacant house and lot. Since we had a right of rescission with this loan the customer cancelled the transaction. Can we charge the customer for his fees incurred with the loan request?
09/27/2015
What disclosures are required for an interim construction loan?
09/21/2015
Is there a minimum font size to advertise credit card rates?
09/07/2015
If a Notice of Right to Rescind (ROR) is provided inadvertently to a customer not entitled to receive an ROR notice -- what are potential impacts? Could the loan be rescindable if they were provided the notice at loan closing?
08/31/2015
On the new Reg Z rules for Agricultural purposes, if we did an ag-purpose loan for say $140,000 or more and we took a 1st on a vacation home on the lake worth about 55,000 as additional collateral, would this loan be exempt from the new disclosures?
08/31/2015
Our institution originated a $170,000 12-month single-pay loan in which interest was due each month. The borrower paid the loan off on the 25th day after consummation. APR was originally stated at 6.097%, however, since the loan was paid off so early, I believe we will be over 21.75% and need to provide a refund to the borrower. My software will not allow me to recalculate the loan with the payoff date as the payment date since it is less than a 30 day period. We have never encountered this before, so therefore, I have two questions:
1) What would be the correct way to calculate the APR on this loan with the payoff date as the first payment date? We use APRWIN but I get mixed results.
2) How do I figure out the refund to the borrower?