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Questions Answered
08/05/2018
For Reg D excessive transfers purposes from savings account, can a bank choose to use calendar month for one customer and statement cycle for another customer when both have the same account type, such as a money market deposit, so long as we use this consistently per customer?
07/29/2018
Can you require a principal pay down on a consumer real estate loan?
07/29/2018
As a bank employee, are we required to provide a magnifying glass or similar to someone who is visually impaired in order to comply with ADA regulations?
07/15/2018
If the bank receives a joint application but one of the joint applicants is a minor, can the bank deny the loan based on age of one
individual (the minor) without facing possible discrimination? Under ECOA an institution may treat credit applicants different when under the age of majority based on state laws. But what if it is joint and the other applicant is of age?
07/01/2018
We have a loan that is a mobile/manufactured home on land. It sits on a basement and has a garage. We are wondering if the fee, $150.00 to the State of Michigan for the Affidavit of Affixture, is to be included in the APR.
06/24/2018
If a borrower requests a home improvement loan for the purpose of adding office space to his home, to allow him space for legal and security work, would this be a business purpose loan, or would it be considered a consumer purpose loan?
06/10/2018
We are trying to set up mortgage application online. We are having debates on what disclosures we need and how to provide the disclosures. Is it something as simple as sending a PDF or does it require us to follow E-SIGN? If the mortgage is submitted online, do the disclosures need to be sent online?
06/03/2018
Is it possible to modify a consumer home loan that has already matured? If not what reg tells us that? Also the loan is in bankruptcy. Where can I find information concerning modification rules?
06/03/2018
In an effort to comply with the notice requirements for force-placed insurance on serviced mortgages, is there any guidance anyone can offer regarding alternative methods of notice delivery other than "first class mail" by the USPS? We have a customer living overseas. I know that Reg B appraisal notices allow for email and LE and CD notices can also be emailed. Your thoughts or guidance in this?
04/22/2018
A borrower signs the Note and receives the rescission disclosure and all the other disclosures on the Note date. After the rescission period passes and the funds are disbursed, can the effective date of the loan that interest begins accruing be the Note date or the date the funds were actually disbursed?
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