If we price HELOCs based on the applicant's credit score and loan to value ratio, so some borrowers get a lower rate than other borrowers, can we disclose the lower rate in our advertisement, or do we need to disclose both rates? Do we also need to specify the criteria for receiving the lower rate?
What does it mean to “automatically clear” exceptions?
There are competing thoughts on the appropriate way to treat an application when the Loan Estimate is not provided by the 3rd business day following the applicant's submission of the six pieces of information. Theory 1 - Cancel the existing application and restart the application process. This may be due to some issues with selling the loan on the secondary market. Theory 2 - Show it cas a "self-identified" issue on the file and continue with the file as is. As long as it is not a pattern in practice and is just a one-off from the established controls, there should be no ramifications. Please help in identified whether #1 or #2 (or may be a 3rd option we aren't thinking of) would be the most appropriate.
We have been presented a check payable to "Estate of ***** C/O ****'." This is the only check that will be issued in this manner. Could this be deposited into the deceased person's joint account or does an estate account have to be opened? The check is for $12.00.
For years, the Consumer Financial Protection Bureau (CFPB) has promised to prioritize rulemaking based on consumer complaints. The proposed rule was released in May 2019, but what effect, if any, does the proposed rule have on first-party creditors? What other regulatory concerns related to debt collection should my bank be aware of?