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Latest Compliance - Reg. Z Topics

Admin fee on consumer loans

02/02/2025

We do consumer loans consisting of auto, unsecured, and CD secured loans, and we charge an administration fee of $25.00. This fee is listed in our third-party document generation and processing system as an administrative fee that affects the APR (in other words, a finance charge). I wonder if this is acceptable for a consumer loan.

Hazard insurance on TRID disclosures

07/14/2024

If I am refinancing a primary residence, do I need to include last year's insurance on the loan estimate and closing disclosure as a POC fee? Or can I just leave it off because insurance and taxes are accounted for on my Initial Escrow Disclosure?

Borrower signatures on Right to Rescind notice

06/30/2024

When a right to rescind is involved in a real estate-secured transaction, we are trying to confirm if there is anything in the regulation that requires the borrower(s) to sign all copies of the notice of right of rescission, or only requires the borrower(s) to sign one copy for the lender and leave the borrower copies unsigned. We can only find where the number of copies to be provided is specified (two for each owner if on paper, one for each owner if delivered electronically).

Prequal Disclosures Required?

03/24/2024

A broker sends a potential borrower to the bank. He wants to pre-qualify for a loan that will be a finished house in a builder's subdivision which is represented by the broker. The dwelling will not be finished for 6 - 12 months. The bank received the application from the broker and pre-qualifies (no pre-approval program) for a later date. There would not be any early disclosures at the type of the pre-qual, correct?

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GMI Collection for a Bank, by a Broker

02/16/2025

If a broker submits an application for a multifamily loan to a bank on behalf of a mutual customer, is the broker required to collect HMDA GMI data? Say the customer "does not wish to provide" the data, would the broker need to collect the information on the basis of visual observation or surname and communicate that to the bank?

Who Gets the Adverse Action Notice?

02/16/2025

Our denial of a business deposit account application was based on the qualifile score of the individual applying for the business. Who gets the Adverse Action Notice?

Inside the CFPB – What’s Going On?

02/16/2025

What’s going on inside the Consumer Financial Protection Bureau (CFPB)? Perhaps the short answer is “turmoil.” Here’s the longer answer, based on what we know as of the date of this writing.

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