10/08/2007
When a CD is renewed for the same term, interest frequency and interest payment method and only the interest rate is changing, are we required to send a separate disclosure that includes all of this information? Since the only change is the interest rate is that all the information we have to provide?
09/17/2007
When we do an in-house renewal of a real estate loan secured by a dwelling we get a new note signed, issue a new loan number and do a modification to the original deed that we hold. We do not extinguish the deed and prepare a new one. Would this still be HMDA reportable as and considered a refinance?
09/17/2007
Currently we mail out a CD maturity notice about a month prior to the maturity date. Once the certificate matures (we have automatic renewal) after the grace period of 10 days, we mail out a renewal notice. If we include the interest rate on the renewal notice, can we also include the APY and are there any specific requirements regarding this? I have read Reg DD and can't seem to understand its specific application to this situation.
08/20/2007
We are in the process of renewing a business loan that was originally done as a two year balloon note to purchase a 1-4 family investment property. There is no additional money being given to the customer. Would the renewal be considered a refinance and be subject to HMDA reporting?
05/28/2007
Our compliance officer maintains that it is a requirement that we update the customer's file with a current application (Form 1003) each time we do a modification or renewal of a real estate loan. My position is that this is not an application since we already have the loan. What if the customer refuses to complete and/or sign it, what can we do? It just seems like extra busy work to require the completion of a four-page application. What do you think?
02/05/2007
In 226.20(a)of Reg Z the following is excluded from the term "refinancing" and therefore exempt from disclosure requirements: (1) A renewal of a single payment obligation with no change in the original terms. Does "single-payment" include a loan where principal is due at maturity (e.g. 12 months) but interest is payable periodically (e.g. quarterly)?
05/22/2006
For various reasons, we have a significant number of auto-renewing CDs on our books that have terms that don't conform to our normal CD terms. For example, we have accounts with 9, 10, 13, 14, 15 and 27 month terms that would continue to roll over into similar odd terms. Management wants to bring these accounts into line with our current offerings, which are for 18 months and 1, 2, 3, or 4 years. Can we renew each of the odd term CDs for terms that conform to our norms, moving each up to the next term in our current offerings? That would move the 9-month accounts into one-year terms, the 13-month accounts into the 18-month term, etc. If so, would we simply state the new term on the renewal notice, or would we need to give more advance notice? For what it's worth, our account agreement says that CDs will renew for a similar term.
04/03/2006
In relation to Reg O, or whatever applicable regulation, where does it state that on the call report the Bank must disclose the entire amount of a Line of Credit? We are working on a Reg O audit, but would like to reference something concrete that states they should disclose the entire amount of the LOC, not just the current balance.
02/13/2006
Our bank is new to HMDA reporting for 2004. If a loan originated prior to 2004 that was for the purpose of purchasing a dwelling or for home improvement, and is now up for renewal, should it be reported now? I understand that a renewal, modification, or extension of existing debt is not reportable for HMDA purposes, but in this case, should it be reported?
01/01/2006
A key element of measuring risk is determining the amount and priority of risk. With compliance regulations, some risks are very difficult to manage in a way that reduces or eliminates risk.