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#1528989 - 03/30/11 06:51 PM Brochures
3 yrs to go Offline
New Poster
Joined: Mar 2011
Posts: 24
I have very recently become the Compliance Officer at my bank in Michigan. We just found some brochures entitled "Criteria for the Approval or Denial of a ____ Loan."

Is anyone aware of any state law that requires we provide these to applicants at the time of application or at the time of denial?

I appreciate your help.

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#1531146 - 04/04/11 05:14 PM Re: Brochures 3 yrs to go
Moving Forward Offline
Member
Joined: Feb 2004
Posts: 56
Michigan
Welcome to the bright sunny side of banking Linda! grin

Without knowing what the brochure covers, I wouldn't be so bold as to give a definitvie answer. However, from the title alone it sounds like an internal brochure. We don't have anything like that in our loan disclosures.

I would also be concerned that they are outdated if you just 'found' them. I'm sure that your bank has gone through it's share of revamping of lending criteria during the last two years along with the rest of us.

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#1531325 - 04/04/11 09:00 PM Re: Brochures Moving Forward
SmallTownGirl Offline
Member
Joined: Jan 2006
Posts: 76
Check out the following link on the Michigan Legislature's website, number 10 at the bottom:
http://www.legislature.mi.gov/(S(kmvf0055s4eqil45kcuh0055))/mileg.aspx?page=getObject&objectName=mcl-445-1602

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#1531397 - 04/05/11 12:54 PM Re: Brochures SmallTownGirl
Moving Forward Offline
Member
Joined: Feb 2004
Posts: 56
Michigan
Excellent information Small Town Girl - thanks!

I didn't take into account that Linda's bank is likely a state chartered bank. We are a federally chartered OTS institution and preempt from certain state lending laws. I'm assuming at this moment that this is one of them as I have never seen a brochure of this type in our institution. However, we all know what happens when we assume, so I've added it to my to do list to verified that our exemption covers it as well.

Linda - you will still want to make sure it is up-to-date and relevant.

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#1538376 - 04/20/11 08:28 PM Re: Brochures Moving Forward
Bartman Offline
Diamond Poster
Bartman
Joined: Oct 2000
Posts: 1,191
Springfield
The brochure requirement is from section 1602 - also see section 1605. (You need a poster, too...)
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Opinions are Bartman's, not those of my employer. "A noble spirit embiggens the smallest man."

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