12/06/2004
I've seen several opinions on this, and I'm hoping you can clarify it for me. It is my understanding based on reading Official Staff Commentary to REG B and REG C , that loan apps taken over the Internet are treated as mail applications. That is also the answer I got in response when posing the question on BOL. However, I've now been told that the usual exceptions for delayed disclosure do not apply to Internet applications. I'm confused, any wisdom you can provide would be appreciated.
11/15/2004
My question is in regards to Regulation B Monitoring Infomation. We are a non HMDA reporting bank. We have received mixed information concerning the collection of the monitoring information on telephone, mail and internet applications. Does the creditor need to complete the monitoring information on telephone, mail or internet applications to purchase or refinance the applicant's personal residence?
09/06/2004
Reg B requires our commercial and ag customers to initial the top of the personal financial statement if applying for joint credit. Annually we mail out blank personal statements to our ag and commercial customers to update the credit files. Do these forms need initials also?
07/01/2004
As required by the FACT Act, the Federal Reserve Board has initiated action to conduct a study on how the credit and insurance prescreening and solicitation system affects consumers.
06/01/2004
FTC has charged a California mortgage broker with unfair or deceptive trade practices and violations of Regulation Z. The significance of the case is twofold.
02/16/2004
Is there any requirement to return paid notes and canceled mortgages or other such documents to the borrower when the loan is paid off? Our management is trying to save time and postage.
01/19/2004
With respect to a real estate loan, we have a Loan Officer who completed and mailed the RESPA Disclosures prior to application date. They think they should not have to mail out any additional RESPA disclosures after we received the application because they had already been given. I question how they knew what figures to use since there was no application giving them the needed information.
12/01/2003
We saw it coming. When the privacy regulation was promulgated, the agencies had to set standards for notifications.
11/17/2003
Disclosures must be signed and dated within 3 days of application. Does this apply if someone applies by mail of by phone?
11/03/2003
Our bank wants to offer loan applications online. The customer can print the application, then submit it in person or mail the application. The customer cannot enter any information online. This application cannot be submitted via the Internet. My question is, we are offering the application in PDF format, which would require the user to download and install the Adobe Acrobat Reader. Is the bank responsible to disclose anything about Acrobat or the link to the Adobe site?