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Latest Compliance - APR/APY Topics

Error on Loans Account (In Customer's Favor)

06/13/2021

During a conversion the bank made an error regarding our loans account in the customers favor. These were paying demand deposit accounts which had been overdrawn. We would like to raise the APR to charge the existing customers the correct rate. Since this would have an adverse impact on the customer, we would have to send the notice to all existing customers, at least 60 days in advance. The question would be is there a sample form that we could utilize to send to our existing customers?

IR Disclosed in Promissory Note is Incorrect

10/30/2016

If the interest rate disclosed in a promissory note is incorrect (it is lower than what is actually being charged), is that a Reg Z problem? What if the TILA disclosure is within tolerance and is considered correct, could this then be an issue with UDAAP?

APR WIN on a time note

09/25/2016

I have a 2 year time note, with interest paid quarterly and a final balloon payment of principal plus last quarters interest. I'm looking for guidance on how to run this through APR WIN.

Disclosure of MAPR in Conjunction With Covered Borrower ID Statement

09/07/2015

Is the MAPR required to be disclosed any time our bank also uses the Covered Borrower ID Statement or only if the loan is a covered loan (closed-end secured by a titled motor vehicle with a term less than 181 days for a purpose other than a purchase)? We are a very rate-friendly lender already and don't want to take a chance on holding ourselves to a yet lower rate if we refinance the loan later on. Under the Talent Amendment, we aren't sure.

APR if Disclose IR In Pre-Qualification Letter?

11/17/2014

If we disclose an interest rate in a pre-qualification letter, must it disclose an APR as well? I know it must for advertisements but I am not quite sure what a pre-qualification letter is considered. It is a true pre-qualification letter, not a pre-approval.

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Church/Credit Union: Non-government Organizations?

08/01/2021

We are going back and forth as to whether or not a credit union or a church are actually considered non-government organizations? Although we know that they are non-profit, I have read conflicting information and am trying to settle this internally.

Handling Reg E claims on older transactions.

07/25/2021

If an EFT claim is made long after the statement is sent showing the transaction, the rules of investigation don't apply. So why do we investigate any of these claims?

Compliance Info on Paper Checks

07/25/2021

I was wondering if you could point me in the right direction as to where to find more information on compliance for paper checks? Whenever I place a stop payment on a paper check, there's a disclosure that says "this request will expire in 6 months in order to comply with regulatory requirements." For the customers who ask for a more in-depth answer, what can I tell them?

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