Most Popular Lending Content
FCRA Signature Required?
10/27/2024
We are transitioning to a new loan software program and have noticed the Negative Information Disclosure document provided at closing is not providing a signature line for the borrower to sign. Our current loan software has the signature line that isn't removable so we have always assumed it was required. I cannot find any information in the regulation that a signature is required. 1) Is a signature required and 2) If it is not required to obtain signature, is it required that we retain a copy of it with the closing package to show examiners it was provided at closing? It just seems odd from what we have always seen and would like to know if we should request a signature line be added.
Late Fees and Insiders
10/27/2024
Overdrafts may be one issue, but what about a late fee waiver on a loan for bank director - would this be a violation of Reg. O?
Can we advertise a credit card product as “fixed” if it has a fixed introductory rate?
10/27/2024
We have a credit card product that has an introductory “fixed” rate that changes after 12 months to a variable rate APR. Management wants to really promote that fixed rate period, but I don’t think we can use the word “fixed”, can we?
Appraisal timing and fair lending
10/20/2024
If a financial institutions normal process for commercial property loans is to start appraisal bids/engagements post-decision, can there be fair lending violations for starting appraisal bids/engagements pre-decision for customers based on length of relationship with the financial institution, credit exposure with the financial institution, etc?
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?