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?
On the Statement of Credit denial, termination, or change. Part I- Section- E. (other) What does this mean: "we do not grant credit to any applicant on the terms and conditions you have requested." Could you please give some examples?
Are indirect auto finance companies required to comply with SARs reporting?
Is there any requirement on classifying a non-dwelling secured home improvement loan (secured by an auto) as a home improvement loan vs. an auto secured consumer loan?
If I take a second REM in an abundance of caution for a loan workout situation, are early disclosures required? The loan was originally an auto loan.
In the past, we discounted our auto rates when a customer set up automatic payments. Going forward, we would like to set our rates sheets at a rate assuming automatic payments and then add 25bps to the rate if the customer does not wish to set up automatic payments. We would determine their wishes before disclosing the rate/APR and only disclose based on their given rate. Do you see any compliance issues with this providing that our rate sheets clearly indicate what is required to get the stated rate?
My job has been to work on residential compliance. My boss has just taken over the servicing side for commercial loans.I have never worked with commercial loans before now. Where would I start? I understand that some of the Reg's encompass residential and commercial. What fees are allowed? Where would those do's and don'ts be found?
We have experienced a change in examiner's interpretation of the "required deposit" box. This has been a Fed Box disclosure for over 20 years. Can you please give me the definition of exactly what a "required deposit" is and when the required deposit box is to be checked.
If your hold is for 5 days and the fifth day is the 25th, should the hold auto release at midnight of the 24th? Or do we have until 9am on the 25th to release those funds?
We are doing a fifteen second radio commercial, and I would like to say that rates start at 1.99% APR on auto loans. How much disclosure is necessary? On a print ad, we always say "Must qualify: actual rate determined by credit score and vehicle age. Rate reflects a .25% discount for automatic payment from a [bank name] account. Existing [bank name] loans do not apply."