08/05/2002
Our bank president wants to begin offering an interest-bearing checking account, which we have never done before. What types of disclosure issues will we be facing?
08/01/2002
HUD has published a proposal to make significant changes to the Good Faith Estimate that lenders issue within three days of taking an application. HUD calls this a "simplification" of the GFE.
07/08/2002
07/01/2002
I'm in charge of our collections department. With the new change in the privacy policy, it's very hard for my collectors to skip trace on mutual customers. What advice do you have for finding mutual customers and charge off? We do a lot of internal collections work.
06/03/2002
When renting safe deposit boxes are banks required by law to give any disclosures to the customers? If so what disclosures would this be? (insurance)
05/06/2002
My bank charges an application fee for closedend home equity loans, which covers all closing costs, including credit report, flood determination, title search, appraisal, and mortgage recording fees. Currently we disclose each of these thirdparty fees as P.O.C. and the applicable amount on the GFE and HUD1A. Another local bank uses a similar method of one fee to cover all closing costs. However, they only disclose the one fee on the GFE and HUD1A, with no references to fees paid to thirdparty service providers. Needless to say, our loan operations would prefer to follow this local bank's example. I believe we should continue our current practice, but I'm having some trouble finding clear regulatory wording to support my opinion. Section 3500.7(a)(2) refers to "no cost" loans, but our loans do have an application fee. Could I have your opinion on how our situation should be disclosed and also a regulatory reference to back that up?
05/06/2002
We are in the process of re-mapping several of our accounts and we will be 'forcing' (for lack of a better word) certain customers into a new account type that may have different fees or terms. The question we have is regarding the 'returned mail' that we received that was the notification of the change itself. The mailing included disclosures, fee schedules and time tables for of the changes. Do we need to retain each peice of 'returned' mail, can we keep a list or can we just keep the associated envelope?
05/06/2002
When renting safe deposit boxes are banks required by law to give any disclosures to the customers? If so what disclosures would this be? (insurance)
05/06/2002
I know that most banks choose to use an outside vendor for IRA forms... what are the advantages/disadvantages of using a vendor or going in-house?
03/25/2002