Does CAN-SPAM apply to those emails sent by platform employees to let their preferred customers know of new rates, etc.?
Are there best practices for tracking loan policy exceptions?
If TILA disclosures are provided in a loan to a business entity and the APR is understated - is this a violation of regulation Z although loans to business entities are exempt from the coverage of Regulation Z?
Should non-RE loans that exceed the dollar threshold for Regulation Z coverage still be considered consumer loans as far as coding and reporting? We have a difference of opinion. One side believes the Reg Z exemption essentially changes the loan into a commercial loan in every way. The other thinks that the disclosures in the documentation is where the exemption is primarily seen and the loan should be coded and reported exactly like any other loan of its type that is under the threshold. Any clarification would be appreciated.
A customer placed a stop pay on a check for $1,600. The bank first processed the deposit as $16.00 so our system didn't stop it and the customer didn't realize it until several weeks later. I have looked everywhere and can't find any case similar to this. Can we return it and if so, for what reason, additional paperwork is needed?