How do banks track disclosures?
Our FI is planning on using Promontory to offer broker deposits to consumers.
I have thought that Reg DD, section 1030.4 thru 1030.6 (Account
Disclosures) apply, however the Agreement and periodic statement don't specifically
address by Reg DD the required elements. For example, their Agreement states
accrued interest will be credited "at least once each month" vs. a specific
frequency, and it does not reference if accrued interest will be paid or not
paid if the account is closed, and refers to the APYE as "Statement Period
We have just received communication from the vendor and they are telling us
that "A Relationship Institution is a “deposit broker” for purposes of
TISA and, as such, is subject only to the advertisement provisions of Reg
DD." But they don't even spell out at least once Annual Percentage Yield.
Is our FI required to meet all the requirements of Reg DD as if the consumer
were opening one or our MMAs?
Would escrow estimates be reflected on the LE/CD on a junior mortgage if those are being covered by the first?
Our bank would like to offer a 20/15, 25/15 and 30/15 loan where the interest rate is fixed for 15 years then changes one time for the remaining term. Everyone we've talked to says these are ARM loans. However, in our loan platform all ARM programs must have a subsequent rate and payment change date. Is anyone else offering these products? If so, how are they disclosing?
Under Regulation E, section 1005.9(b), Banks are required to include the type of transfer and the type of account to or from which the
transfer was made. The commentary doesn't specify how you disclose the type of account under this section (however, it does specify how to disclose this
for terminal receipts under 9(a)). So, my question is, is it OK that our periodic statements just state "transfer from account XXXX" instead of
specifying the account type or should it be stating transfer from checking/savings?
Is prepaid interest included in the calculation for Total of Payments amount in the TRID Loan Estimate and Closing Disclosure?
What disclosures are required on an annual IRA statement?
Are Reg DD disclosures, especially the APY required when, for example, a customer negotiates a bumped up rate for 3 months?
We are moving our accounts to a relationship style checking with service charge refunds with certain transactional behavior.(ACH, POS, eStatements,etc) What are some considerations we need to remember when building the TIS disclosures?
How can we automate the tracking of our disclosures?