Most Popular Lending Content
There are GAPS in your CMS and they involve lending!
05/07/2023
Do you think you have gaps in your fair lending and CRA program?
HELOC Itemized Disclosures
05/07/2023
I am looking for some clarification on disclosing the finance charges section which states the components of the finance charge shall be individually itemized and identified to show the amount(s). Start up fees - charges are financed as part of the plan, including charges that are paid out of the first advance, charges must be disclosed. My question is, we have a HELOC that financed all fees into the loan. Our operations department was told to list them individually. However, they combined the Recording and E-Recording fee as a single total, with the description of Recording Fees. Then the Title Insurance fee and Title Services fee were shown as a combined total with the description, Title Insurance Fee. Would this suffice or should they truly be separated out? My recommendation was to list them all out, to mitigate confusion but our operations team is unsure if we can add the additional fee modifiers to our banking system.
There is a new threat to your FI’s CMS!
04/30/2023
Do you know what the new threat is to your CMS?
Getting an “As Is” value with the Appraisal
04/30/2023
My appraiser has indicated they can’t include an “As is” value in the same report as a “Subject to” value. He is saying it is a USPAP violation. Is this correct?
Our deposit account vendor told us a slight APY error is no problem – are they right?
04/30/2023
We have noticed that the APY is wrong on some of our Truth in Savings disclosures, but only by .03%. The APY is calculated by our document software vendor, and they told us not to worry about it, because Reg DD has a +/- .05% tolerance allowance. Is this true?