When a customer violates Reg D for the third time, we take away whatever was abused; such as internet transfers, ACH etc. Can we give what we took away back to the customer or is it gone for good, or do we not take away something and just close the account? I'm not sure what is a best practice.
We have a customer wanting to open an Professional Limited Liability Company. What should the bank get for documentation? Do we need the Admission to Transact Business and Articles of Organization?
Regarding a lender credit reduction for an extension of an interest rate lock, may a lender reduce a lender credit to extend the lock period? Example; A rate lock expired 4-25-19 and the closing date was 4-28-19. The initial rate lock and Loan Estimate reflect a lender credit of $2000.00 with 4.25% interest rate. The lock was extended through 4-29-19 at the same rate, but the lender credit was reduced to 1800.00. Since the lender credit was reduced based on an interest rate dependent charge, is this acceptable for interest rate extensions? If it is, is there a requirement that documentation confirms the delay was due to the borrower or outside of the lenders control?
Does Reg D apply to a savings account that has been used as security for a loan?
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?