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?
Can a non-loan originator employee (teller) receive referral fees for loans that close in the secondary market, but receive no or less compensation for referrals of loans that close in-house?
Does a security agreement for "All Assets" include and cover a motor vehicle that is titled?
If we offered a HELOC teaser rate in the past, does that APR need to be reflected in the Application Disclosure Historical Index Table? The Official Interpretation of 1026.40(d)(12)(x) 4. Amount of discount or premium. This uses the word "may."
Can email notifications be sent for abandoned property? My understanding is that this is subject to what each state may require depending on the address the account holder is located. Some states require a written notice to be mailed. So if we meet E-SIGN requirements would that supersede state requirements? Would CAN-SPAM Act also need to be considered as not being in violation since it talks about "notification of a change in the recipient's standing or status"? I'm thinking this Act is more related for purposes of commercial electronic mail.