01/26/2009
The bank is thinking about conducting a mass mailing of debit cards to all customers who do not currently have a card. I understand that this may be done so long as we follow Section 205.5 of Reg E. The question is, can we exclude customers age 70 and over from the mailing? All of our accounts have overdraft coverage. I am concerned that due to that fact, the regulators might construe the coverage to be incidental credit, which could potentially mean an age discrimination issue per ECOA. I know that the bank can offer a product that benefits persons over age 62. Do you think excluding those over 70 (or 62) would be a benefit or a detriment? Do you think we can exclude the customers over age 70? Do you think we could use Regulation B's definition of "open-end credit" to get around the "incidental credit" issue?
10/10/2008
06/30/2008
When a loan is declined within three days of application, the early RESPA disclosures are not required. Are the Reg Z early disclosures required? I can't seem to find anything in the regulation that would exempt denied loans from the early TILA.
05/28/2007
We do lot loans to consumers. I was told I needed to furnish the consumer with a Good Faith and Truth in Lending on a lot loan. Is this correct? Do RESPA & TILA apply to lot loans?
03/12/2007
We have a non-RESPA Auto Loan under 25,000.00. The credit file is missing the signed final TIL. Is this a Reg Z violation and should we redisclose?
05/22/2006
Are there any specific size/readability requirements relative to disclosures for Member FDIC,Equal Housing Lender Logos, and, if applicable, disclosures relative to TISA or TILA on billboards? I'm having difficulty understanding what is meant by "clear and conspicuous standards" and am interested in knowing if there are standards for the readability of these disclosures? Is there an industry practice relative to inches of fonts (regardless of the size of the billboard)?
12/05/2005
Does a wholesale mortgage lender need to re-disclose under Reg Z and TILA to a borrower who has already received these disclosures from a mortgage broker?
08/15/2005
Our Loan processor has added the capability to print out the FACT Act Negative Notice Disclosure with the new loan paperwork. The Negative Notice is a separate document. My concern is the Notice would be considered being included in the initial disclosures. I understand that the Negative Notice could not be provided with the initial disclosures under the Truth in Lending Act.
01/03/2005
Of all the settlement fees that can be found on a HUD and GFE, which ones should be marked as a prepaid finance charge? Or, if it's easier, what shouldn't be marked as a prepaid finance charge?
08/23/2004
Add "V" to Your Regulatory Alphabet
by Mary Beth Guard
Guru BIOS