05/26/2024
My understanding is that Fannie Mae requires that a seller/servicer have an internal appraisal reviewer that solely reviews appraisals. If so, must this individual be licensed as an appraiser?
05/26/2024
My bank just received an SCRA request for rate relief on a customer’s credit card line. The card normally has a 22.99% interest rate, so 6% is a big drop! How do we do it? Is it only on existing balances up to this point, or does it need to remain at 6% for all past and future transactions, until his active duty ends?
05/19/2024
In terms of UDAAP, what makes something “Abusive”?
05/19/2024
We have an employee that serves as the bank's Bankruptcy Officer. This employee does not lend directly to the public. They do not have an approved lending limit. This employee negotiates with the trustee/court/lawyer/borrower on an active bankruptcy to restructure loan terms according to the bankruptcy agreement.
Would this employee need to be a registered MLO (SAFE Act) if they are negotiating terms for an active bankruptcy on a consumer mortgage loan?
05/19/2024
Does the FFIEC APR Calculator work for HELOCs?
05/19/2024
My bank has just acquired another bank that has its own in-house credit card program. We’ve purposely never done an in-house credit card program because of the sizeable compliance burden of them, but now here we are. What do I need to know for compliance on these acquired cards?
05/12/2024
Where does the CFPB’s authority come in when they determine something is “Abusive”?
05/12/2024
My bank is doing CD specials a lot lately, and with rates being higher, there are now actual differences between the interest rate and the APY. I want to get it right! I’m concerned that something is wrong with our 13 month CD special (interest paid at maturity), because the APY is LESS than the interest rate. How can this be?!
05/12/2024
Can you provide guidance on what is considered an outside source? On the Notice of Action Taken in the Disclosure of Use of Information Obtained from an Outside Source, what would be considered an outside source. We have a customer where the denial is based on “Collection Action or Judgment” which was identified when the account officer did a search through our State’s website. Would this constitute such a disclosure and if the borrower wanted to request a copy as they have a right to would we simply give them the name of the website?
05/12/2024
Is it true that people under the age of 21 are not permitted to get their own credit card?