02/20/2022
Our current periodic deposit account statements show all the required parts for compliance required at 1030.6(a). We show the APY Earned based on the General Formula from Appendix A-2.2.A. If we decide to remove only the “Interest Rate” reflected on all periodic deposit account statements going forward, could we be out of compliance with 1030.6(a)? Also, if we continue to leave the interest rate on the periodic statements, would it be an UDAAP issue, potentially causing confusion for consumers to see a different interest rate on periodic statements than what is on their TISA, due to fluctuations on deposits and debits?
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?
05/13/2018
Is there a requirement on how many places after the decimal point to use when quoting rates on a rate sheet or advertisement? Two or three places?
05/13/2018
Is there a requirement on how many places after the decimal point to use when quoting rates on a rate sheet or advertisement? Two or three places?
02/11/2018
What all is required to advertise a special CD rate on an outside digital board? Does APY have to be spelled out? Is this sufficient?
12 Month CD 1.26%APY ASK US
10/01/2017
If we use postcards to advertise consumer loans can the APR disclosure be on the flip side or does it have to below the APR on the same side?
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?
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.
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.
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.
