10/30/2016
If the interest rate disclosed in a promissory note is incorrect (it is lower than what is actually being charged), is that a Reg Z problem? What if the TILA disclosure is within tolerance and is considered correct, could this then be an issue with UDAAP?
07/15/2013
I am wondering what the possible penalties to a lender are for non-compliance or improper execution of Right of Rescission.
07/15/2013
RESPA/TIL question: We have a residential purchase loan where the attorney who closed the loan did not (also) provide the title insurance policy. FDIC states we have a TIL violation b/c we did not disclose the attorney's fee as a prepaid finance charge. We are not familiar with this being a part of TIL. Your thoughts please.
03/25/2013
Regarding overdraft repayment plans: Reg Z disclosures will be triggered if the loan is payable by written agreement in more than 4 installments. So, as long as the written agreement says 4 or less payments, may the consumer make bi-weekly payments totalling 8 payments until paid in full and still be compliant without giving Reg Z disclosures?
01/21/2013
Have you heard of the obvious error rule? The FDIC has recently completed a compliance exam and mentioned the obvious error rule in relation to the APR calculation on open-end credit.
12/17/2012
Are banks permitted to charge a fee to customers or non customers to withdraw funds using their Visa debit card (inside the bank not by ATM)?
10/08/2012
We have just had a compliance exam and they said that we have included the document preparation fee as a prepaid finance charge. We are listing it on the GFE in origination fees. Is this not right.? If not, where do you put it on the GFE?
08/27/2012
Our open end consumer loan agreements (demand deposit loans) read: a finance charge will be assessed on the daily unpaid loan balance and I believe it should read interest charge will be assessed. Which is correct to be in compliance with regulation?
04/16/2012
If part of line 801 "Origination Fee" is broken out as Doc Prep Fee, can that portion be excluded from the Finance Charge for TILA?
03/19/2012
On the new Truth in Lending section under prepayment penalties, are we required under Reg Z to refund a part of the finance charge (like origination) if a loan is paid off early? Is it a state/regulator specific requirement? Or can each individual bank decide if they want to refund or not?