07/02/2007
We are a national bank and a member of the FDIC. On our internal calculation of the past due ratio, non-accrued loans are being subtracted from total loans and then non-accrued loans are not considered in the 30, 60, 90+ days past due. Should non-accrual loans be included in total loans since they are loans outstanding? Is there any OCC or FDIC rule that either supports using non-accrual loans or states that non-accrual loans are not to be included in the calculation of total loans and past due percentage?
06/18/2007
A borrower is applying for a home equity line of credit with our institution. An appraisal was done within the past year as part of a refinance of the first mortgage through a mortgage company. The combined loan to value is sufficient using the existing appraisal. The appraiser is one of our approved appraisers and the appraisal will be reviewed by us as well as a property verification performed. Are there any restrictions regarding the use of the existing appraisal? I am specifically asking if it is required that this appraisal be originally ordered by an FDIC insured financial institution or can we determine if the source is acceptable?
05/28/2007
Are the Federal Insurance Disclosure for Credit Application form and the Credit Insurance Disclosure form (which is usually with the Disbursement Request and Authorization form) two different things and do both need to be signed for consumer loans?
05/14/2007
What percentage of capital can a bank have in real estate loans with a loan-to-value greater than 80%?
04/09/2007
I have heard that the revised regulations for advertising membership in the FDIC no longer exempt ads for loans. Is that correct, and was a similar change made to the NCUA regulations?
03/12/2007
This question is about placing an ad in the newspaper for commercial lending. I assume we don't need to have the FDIC logo in the advertisement, but do we need to state that we are an equal credit opportunity lender? Is there a requirement that says we must state that we do not discriminate on the basis of race, religion, etc.? We thought we would include it anyway, but we are having trouble finding where it specifically states that for commercial lending advertising.
03/05/2007
This question is about placing an ad in the newspaper for commercial lending. I assume we don't need to have the FDIC logo in the advertisement, but do we need to state that we are an equal credit opportunity lender? Is there a requirement that says we must state that we do not discriminate on the basis of race, religion, etc.? We thought we would include it anyway, but we are having trouble finding where it specifically states that for commercial lending advertising.
02/26/2007
I am trying to update all our signs on the teller windows. I need to know all the signs that we are required to have on the teller windows besides FDIC. Do you have a list of requirements and where they need to be? (Funds availability, fee schedule, check cashing policy, etc.)
02/12/2007
Is it a consumer law that you can't have a payment date of less than 30 days and more than 45? If the loan date is December1,2005, can you make the first payment date due on December 10th?
11/13/2006
We are planning a home lending TV Commercial. Do we have to show the FDIC Member and Equal Housing Lender logos in the ad or is stating that we are an FDIC member and an Equal Housing Lender enough?