Most Popular Lending Content
Late Fees and Insiders
10/27/2024
Overdrafts may be one issue, but what about a late fee waiver on a loan for bank director - would this be a violation of Reg. O?
Can we advertise a credit card product as “fixed” if it has a fixed introductory rate?
10/27/2024
We have a credit card product that has an introductory “fixed” rate that changes after 12 months to a variable rate APR. Management wants to really promote that fixed rate period, but I don’t think we can use the word “fixed”, can we?
Missing or incorrect file number on mortgage closing disclosure
10/27/2024
Is it a TRID violation if the File # is missing or incorrect in the closing information section of the closing disclosure?
Selective reporting to credit bureaus
10/20/2024
As part of an initiative to be able to sell to secondary market we need to set up reporting to all credit bureaus. Currently we only report to Equifax. I am wondering if there are any compliance concerns if we only report to all bureaus for some loans (mortgage loans) and not others (in house branch originated) or mortgages vs. other loan types, commercial vs consumer, etc?
Call report codes and agricultural use land
10/20/2024
We have a number of residential loans that sit on several acres of property that i would consider 1B if it were vacant, i.e., "usable for agricultural purposes." Should these be classified as 1C2A or 1B on the Call Report? The definitions leave room for interpretation. For example, a loan for a single family residence that sits on 100 acres.