10/07/2002
I have a RESPA / Reg Z question that I am hoping Lucy Griffin can help me with. In some cases, a lender will waive or reduce a fee on a RESPA-related loan. When this is disclosed on the GFE and HUD-1 or HUD-1A they will list the full fee and then insert a lender credit on one of the empty lines in Section L on the form(s). Sometimes they determine up front that they will waive or reduce a fee, but they still list the full fee with the lender credit as a separate line item. Sometimes the fees they decide to reduce or waive are prepaids (for example points). The APR is calculated using the full fee in the amount financed calculation. Is there a problem with recording fees this way - either with RESPA or Reg Z? Based on Q12 in OCC's AL 2000-5, it seems that this would work basically like a coupon and would be okay, although it is disclosed in Section L rather than Section J (I'm not sure why they recommend Section J since there isn't one on a HUD-1A).
09/16/2002
Someone asked me a question regarding changes to the Fair Lending Act and TruthInLending Act that will be effective 10/4/02. I was not aware of any changes. What, if any, are they?
08/12/2002
I am brand new to the Banking Industry as a Compliance Analyst. I've been asked to design fair lending, reg z til and respa test programs. I have no idea where to begin...are there any templates out there that can get me started?
05/06/2002
Our institution wants to develop a behavioral scorecard for delinquent accounts for collection purposes. The only information I can find regarding scorecards and fair lending deals with evaluating creditworthiness in making the initial loan decision. Is there any information about reevaluating credit once it has gone bad? They want to use age as an attribute. Do I need to be concerned?