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Lobby Advertising

07/09/2023

We often have lobby posters advertising products, services, benefits like trips on a discounted price and others things on display so staff can answer questions on these and to promote these items. Do they require the general FDIC advertising statement>

Rate sheet content

06/25/2023

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?

Difficulty using the FFIEC APR Tool on a HELOC

05/14/2023

I’m trying to use the official APR Calculator to confirm that the rate on our HELOC disclosure is correct. I’m so confused! Nothing seems to work, can you give me direction?

Are LPOs the answer?

04/30/2023

Will Loan Production Offices help in fair lending if we decide to close branches?

Is a post-Closing Disclosure needed for an APR error?

04/16/2023

An auditor just told us we have an APR violation (but not a TRID violation) on a consumer real estate loan, that that we need to make restitution to the borrower. Don’t we need to send a corrected Closing Disclosure too?

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Applications, Reg B, Fair Lending

11/24/2024

Can you remove the primary borrower off a pending loan? I was under the impression that as long as both borrowers were married, and they both completed the application and received the initial disclosures that the primary borrower could be removed and the co-borrower moved over to the primary borrower position. This was the only way, and any other attempt would result in a denial, or withdrawn application. We have done this with a couple of our loans, but upper management wanted documentation stating that this can be done.

HMDA reporting and loan purpose

11/17/2024

If we have a consumer HELOC denial with the stated purpose of "purchase land to build a gas station," is it HMDA reportable?

HELOC historical table and SOFR

11/17/2024

Reg Z section 1026.40 requires us to disclose a historical table to reflect the most recent 15 years of index values. However, SOFR has only been available since 2018. Do we only need to disclose the years starting from 2018 even when the length of the plan is more than 15 years?

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