Most Popular Lending Content
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?
Missing or incorrect file number on mortgage closing disclosure
10/27/2024
Is it a TRID violation if the File # is missing or incorrect in the closing information section of the closing disclosure?
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?