11/10/2024
I continue to get push back from our lenders to change rates when we have Administrative Renewals. Reason for an Admin Renewal may be that the customer does not have a current Tax Return or Personal Financial Statement. Our current practice, when doing an Admin Renewal, is to only extend the maturity date by 90 day and make NO other changes.
Is anyone else making rate changes at the time of Admin Renewals or doing them for longer than 90? Is this a regulatory issue with commercial and/or consumer loans and if so, what regulation would we be violating?
05/26/2024
Does any regulation require an institution to send a reduced rate letter when adjusting the rate due to an SCRA claim on a loan?
03/10/2024
If our bank does not offer a rate lock program and all of our loans are fixed rate loans, can a buyer purchase discount points to lower the interest rate? If they can, do they have to sign a form reflecting the discount rate or can we just disclose the discount and fee on the loan estimate?
12/31/2023
The initial and locked Loan Estimate (LE) on an ARM loan was based off the WSJP index. When it was time to issue the initial Closing Disclosure (CD), the WSJP index had increased causing the APR on the CD to be about 1/2% higher than on the last LE. Should we adjust the index value on the CD to match the index value used on the LE to keep the APR within tolerance, or do we need to update the index value to the current value and redisclose the LE and then inssue an initial CD?
12/03/2023
Is there any requirement to disclose the specific rates used to calculate purchase, balance transfer, and cash advance APRs in the credit card agreement, if that information is already clearly disclosed with all other required pricing information (as defined in Reg Z 1026.6(b)(2)(i) through (b)(2)(xii))? This is already provided on our Interest Rates and Fees Disclosure form provided to the applicant with the card.
For example, our credit card agreement (a separate document from the Interest Rates and Fees Disclosure) includes "For the non-promotional purchase and balance transfer APR, we add X.XX% to the Prime Rate. For the cash advance APR, we add XX.XX% to the Prime Rate. However, all of this information is also disclosed on our Interest Rates and Fees disclosure, which is given to the applicant with the Account Agreement and card.
09/24/2023
Are we able to have a floor interest rate on home loans? Is there any regulation on this?
06/18/2023
We have a home equity application disclosure that has a lower Annual Percentage Rate stated than it should be. The disclosures shows in error 4.0% in the minimum payment requirements paragraph where it should be 8.25%.
Is this something that we can fix or is this a rate we must now live with?
05/15/2022
Do you need to modify or prepare a change in terms on a commercial loan when lowering the interest rate but not changing the maturity date? Can it just be done with a maintenance request?
02/06/2022
What regulation dictates the interest basis for a second mortgage?
01/16/2022
I have a question pertaining to an existing ARM loan that is currently tied to LIBOR. For this particular loan the rate adjustment period is annually in April understand that LIBOR will no longer be available after December 31, 2021, but can the bank wait to adjust the index until April 2022?