04/13/2025
We added an E-sign fee to our HELOC in July 2024. On a couple of loans booked after that the new fee was forgotten and not charged. What should we do to rectify this?
07/18/2011
We have been getting conflicting answers on this question. For a personal consumer loan (car, secured, etc), if the customer pays the application fee out of closing (POC), do we deduct it from the amount financed? Example: Customer is getting loan for $2500.00 and she paid the fee herself instead of from proceeds. Would the amount financed be $2500.00 or $2375.00? We have been told to do it both ways. What is the correct way?
05/22/2006
We refer customers to an outside vendor for Merchant Services. The company we deal with has created an incentive program for these referrals. They have submitted one of our employees a check in the amount of $50 for a referral that resulted in a sale. I have read and understand the RESPA implications in regards to referrals in the mortgage lending area, but what about the Deposit side of the bank? Do we allow the employee to accept the check?
05/02/2005
Our institution wants to increase the late fee on loans from $10.00 to $25.00 (all loans). I know we may change the fee for the new loans but what about the existing loans on our books? Is it possible to change the late fee to existing loans with the required notice advising customers of the change?
04/01/2005
There is a common denominator to the leading issues on the compliance front burner. The issues are all point generated by concerns that consumers may not be treated fairly.
10/01/2004
In Advisory Letter 2004-10, the Comptroller of the Currency advises national banks on credit card marketing and account management practices that may be unfair or deceptive.
07/01/2004
When it comes to designing marketing campaigns, the marketing staff tends to view compliance with some skepticism - if not outright hostility.
06/01/2004
When the lifeguard says it's not safe to go into the water, it is generally a good idea to stay out - and dry.
12/01/2003
According to Anna Alvarez of the OCC, the critical issue of CRA used to be access to credit. Today, the issue is credit at what price.
08/01/2003
We are seeing a great deal of discussion about the evils of many kind of lending, and the evils of many financial industry practices.