Most Popular Lending Content
Regs not “fair lending” but are
05/14/2023
How are regulations that are not the fair housing act, fair lending regulations?
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.
When a Borrower isn’t Happy with an Appraisal
05/07/2023
If a borrower is not happy with their appraisal, should I order a second one?
How can a CD’s APY be less than the interest rate!?
05/07/2023
My deposit account software is telling me the APY on our 15 month CD (interest paid at maturity) is LESS than the interest rate. What?!
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?