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Latest Lending - Regulators Topics

Lending Production Office, FDIC Signs Required

05/24/2010

We have several loan production offices. They don't have cash drawers, are not listed as branches, and they don't service the deposit customer walking in off the street. Do we need signage such as the FDIC stickers? What if a courier for the bank picks up some proof work where only our employees make deposits instead of running to a branch?

Paying/Returning Debit Card Transactions

04/19/2010

Where can we find information about paying/returning debit card transactions? Would we have to find out from MasterCard? Management wants something in writing about why we have to pay those when a customer is already in the negative. They are worrying that we could pay something over our legal lending limit and then get in hot water with our regulators.

Info To Realtors

09/14/2009

Our Lending Department has created a “fact sheet” to be given to realtors. The understanding is that these fact sheets would not be provided to consumers. Do you think I could consider these as not being an advertisement, and therefore not having to worry about trigger terms?

Reg CC - Banking Vs Business Days

07/13/2009

Regarding Reg CC Compliance and differentiating between banking and business days: I thought a banking day was a day when a branch may offer hours and basic services(i.e., a Saturday), but not all services are available to a customer, whereas a business day is Mon-Fri (excluding holidays) when all services are available. Now I am reading in a tutorial that a banking day must be a business day, so Saturday should never be considered a banking day. What is your answer?

Handling the Interest on a Loan Renewal

05/04/2009

When renewing a note loan, is it necessary to collect the interest due at maturity or can it be added back to the principal balance of the loan?

Percentage of Exception Loans

02/16/2009

Is there regulatory guidance on the amount or percent of exception loans (i.e. LTV, D/I, credit score...) that can be made relative to your portfolio?

Credit Policies

11/24/2008

Our regulators have requested that our bank more clearly define and document its credit policies. What should be included?

Examiner Verification of RCV on Comm Property

06/16/2008

Now that the NFIP changed the flood insurance coverage to take into account the replacement cost value (RCV) where the appraised value was previously used, how will this affect commercial buildings? This change appears to make more sense for single family dwellings due to the equation (lesser of the debt, value or max coverage available). How will the examiners verify the RCV on a commercial property?

Use of Evaluations in Lieu of Appraisal

06/09/2008

We are aware of the requirement for a full Title XI appraisal for loans over $250K and secured by real estate. However, if there are multiple properties involved, the value of each being less than 100K, can evaluations be used instead?

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45 day letter/forceplacement time frames

12/15/2024

We have a question on the 45 day letter/forceplacement time frames. Can you give an example of the timing when a policy expires on 12:01 am on April 1st. The 45 day letter would go out on the 1st, when would you actually forceplace; the 46th day after the date of your letter? Please also clarify the FEMA lapses due to funding. Were you saying that if we have a FEMA policy in place and the government lapses the program, we are required to have them obtain a private policy or we need to start our 45 day forceplace process until the government reinstates the program?

Life of the loan

12/15/2024

What does the phrase “life of the loan” refer to?

Force Placed Insurance Question

12/08/2024

We are looking into changing our procedures regarding force placed insurance, on both hazard and flood. Currently, we have been increasing the principal balance of the loan and including the premium in our coverage amount. We have not however; on flood, been pulling another flood determination or providing a new flood notice. We thought since they were “life of loan”, we were ok. We are wanting to change the procedure, to adding the force placed insurance as a fee and renewing/charging at time of balloon. My question is…are we in compliance if we only cover the principal balance and not include the payoff (which will contain our premium)?

TRID Question

12/08/2024

We closed a refinance transaction on Monday and gave the 3 day right of rescission. The loan was for $250,000 and is a 15 year. This morning he contact us and they are starting to worry about the payment amount on the 15 year. They are asking if they can pay down $50,000 and change the term to a 30 year. We have not ever had this happen. Our question is does this trigger then to use the 3 day and cancel the transaction and start over or do we fund the loan into our MPF program, wait the 60 days and then do a modification?

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