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?
On interest bearing accounts, must a bank whether in person or via online e-disclosures provide a rate sheet to their clients or is this discretionary?
We are looking into providing electronic NSF notices; OD first OD and current balance; loan payment reminders and past due reminders; CD interest payment due date; CD renewal-maturity date with current balance; CD Maturity-Maturity Date and Current balance; and loan balance notifications all through mobile alerts. This will be provided through our core and not through our online
banking/mobile product. We are mainly focusing on providing the NSF and OD notices through mobile alerts at this time.
I found on BOL your webinar “E-SIGN – Use it Write or Not at All” and wondered if this would apply or is there another webinar that would assist us to make sure we comply with our intention of these electronic notices and disclosures through mobile alerts?