Most Popular Lending Content
Avoid UDAAP in advertising.
05/05/2024
What is your opinion of offering a checking account that offers add-on third party benefits as a feature of the account? Customers are only able to obtain the add-on services if they buy the account and pay the service charge disclosed for this product.
Appraisals, Values and Exceptions
05/05/2024
Assume the following terms on a loan to an individual to purchase real estate: The purchase price is $100,000. The borrower wants to add an additional tract of land in lieu of paying any cash down. The land is owned free and clear and is valued at $30,000. This results in a loan amount of $100,000 with total collateral value of $130,000 and a loan to value (LTV) of 77%. Am I right in thinking that I will have a loan to cost exception and not an LTV exception? This loan would not need to be reported against the banks 30% of capital limit on commercial real estate exceptions.
Compliance Management: How often should I test APYs and APRs?
05/05/2024
How often should compliance be testing APY and APR accuracy? I rely on our expensive software to get it right. Is that OK?
Score obtained but not utilized in loan decision.
05/05/2024
If a loan is denied based on collateral but our credit reports include the credit score, is there anything wrong with include the applicants score on the Notice?
Email Subj: Can business accounts pay a higher overdraft fee than consumer accounts?
04/28/2024
We have significantly reduced our overdraft fee pricing for consumer checking accounts. However, we have left the business account pricing alone. This is OK, right, since the focus of unfair overdraft fees has been on consumer protection?