Vendor Guru Q&A - Lending

Latest Lending - Credit Cards Topics

FDCPA is important to banks

12/19/2021

Why am I concerned with the FDCPA since it applies to third party collectors?

If we have a rate sheet that we give to real estate agents and our loan originators, but we know the true use will be for them to hand it to consumers or post it where consumers can readily access it, wouldn't we need to have the APR on it?

Using the EHL logo

08/01/2021

We include the Equal Housing Lender logo in all our home loan ads. Are we also required to include the “Equal Opportunity Lender” logo?

Can I copy an ID?

07/11/2021

Ever since CIP we started keeping copies of IDs in our files. Is this OK?

AAN? We don’t make those loans.

06/13/2021

During the PPP loan programs we had many requests, but we were not participating? These are commercial requests and would be subject to Reg B. Were adverse action notices required?

Differences between MAPR and APR

03/07/2021

What is a MAPR?

Eligibility for SCRA rate cap

02/28/2021

A soldier’s mother called to tell us her son joined the Army. Do we have to reduce the loan rate that day?

Military Status and Foreclosure

02/14/2021

If our borrower hasn’t requested SCRA protection and is past due on her mortgage, can we start foreclosure as we normally would?

Redlining is real

02/07/2021

Is redlining real? It seems to be an antiquated type of violation.

MLA - Open-end and ODP Coverage

02/07/2021

The Military Lending Act does not specify if the Act applies to an open-ended Overdraft Protection line that is tied to a checking account or a closed-ended loan secured by the applicants’ deposit accounts such as a savings and/or certificate of deposit. Does the Rule apply to both consumer credit types?

Selective reporting to credit bureaus

10/20/2024

As part of an initiative to be able to sell to secondary market we need to set up reporting to all credit bureaus. Currently we only report to Equifax. I am wondering if there are any compliance concerns if we only report to all bureaus for some loans (mortgage loans) and not others (in house branch originated) or mortgages vs. other loan types, commercial vs consumer, etc?

Call report codes and agricultural use land

10/20/2024

We have a number of residential loans that sit on several acres of property that i would consider 1B if it were vacant, i.e., "usable for agricultural purposes." Should these be classified as 1C2A or 1B on the Call Report? The definitions leave room for interpretation. For example, a loan for a single family residence that sits on 100 acres.

Latest Lending - Credit Cards Topics

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