11/19/2012
Our bank is completing an application for a second mortgage closed-end loan. The annual percentage rate quoted on the loan resulted in the application being identified as a high-priced mortgage loan. Are we required to establish an escrow account for this transaction?
11/19/2012
I'm still unclear regarding the effect of the appraisal regulations under Regulation Z on commercial properties. Do the appraiser independence requirements apply to commercial properties?
11/19/2012
We are concerned about the legitimacy of credit card checks submitted for deposit. Under Regulation CC, can we place an extended hold on them?
11/19/2012
I am preparing an adverse action notice for a denied application, but the applicant does not have a score on their credit report.How do I complete the credit score portion of the adverse action notice when there is no score? Can this section be omitted?
11/19/2012
Must a Home Equity Early Disclosure be given to a borrower three days prior to closing or within three days of application?
11/19/2012
I have an application for a commercial loan from two companies. Both are owned by the same investors, but the two companies together are applying for the loan. Do I need to document both companies' "joint intent" when this happens?
11/05/2012
Is GAP insurance an APR fee? Sometimes we add GAP insurance premiums to our auto loans. It is a flat fee that the customer has the option of purchasing. If they purchase it, the loan amount is increased to include the fee and we pay the insurance company from the proceeds.
11/05/2012
Our bank has hired a new mortgage loan originator who was already licensed under the state NMLS system. Must we obtain new fingerprints when we register the loan officer as an employee of the bank?
11/05/2012
Does a customer have the right to dispute an appraised value given to him by an appraiser that he feels has not given him proper appraised value? Does the customer have the right to request another appraisal to compare the first appraiser's opinion?
10/29/2012
Can a bank be at risk for a UDAAP violation by offering an overdraft opt-in program?