Our new TILA does not have the term on it example: 5 payments at $350.00 with a balloon of $2000.00 Is this correct for a fixed rate decreasing with a balloon?
What is the regulatory definition for risk?
Regarding the HMDA Rate Set Date: if a borrower changes the term 120 to 240 months or the loan amount after the initial application, but the interest rate dosn't change, and we normally have the rate set date as the date of application, would the rate set date change for any circumstance other than if the interest rate changed?
If a client calls on the phone to begin a verbal application, and once we notify him of his credit rating and subsequent interest rate, and he wishes to cancel his application and not continue, do we have to continue with the application or can we cancel out the application, citing that he does not agree to the interest rate as the reason for cancellation?
Reg. Z defines an HPML as "a consumer credit transaction secured by the consumer's principal dwelling with an annual percentage rate that exceeds the average prime offer rate for a comparable transaction as of the date the interest rate is set by 1.5 or more percentage points for loans secured by a first lien on a dwelling, or by 3.5 or more percentage points for loans secured by a subordinate lien on a dwelling". Can a loan with an APR equal to the APOR plus 1.5 or 3.5 (as appropriate) be considered to be an HPML, or must the rate exceed the APOR plus 1.5 or 3.5? Am I over-thinking this?
Under the extended FDIC TLGP program, are IOLTA accounts restricted to an interest rate of twenty-five basis points or less? These accounts are addressed separately from other NOW accounts in all the material I have received.
With regard to Reg DD, if I change an account term which previously earned interest on any amount to a minimum balance requirement of a determined amount to collect interest, does this require thirty day disclosure or does the variable rate disclosure handed out initially cover the change?
Our bank is planning to advertise a tiered-rate savings account. We want to make sure we disclose the APY correctly in the ad, but our rate structure is a little different from anything I've seen before, so I need a little help. We'll pay an interest rate of 0.50% on the portion of an account's balance from $0 through $5,000; plus 2.00% on the portion of the balance from $5,000.01 through $50,000; plus 0.10% on balances above $50,000 (all rates are variable, and these rates are what we would currently use). I seem to remember something from an old compliance training class about APY ranges. Is that the direction I should be headed?
Community Bank does a consumer loan that is secured by a CD, but not 100% secured. Maturity dates for both loan and CD are consistent. The loan interest rates on CD backed loans are usually 1% over the interest rate being paid on the CD. Can the bank still charge this interest rate if loan is not 100% CD secured?
Is it legal to pay to only a few customers a higher interest rate than disclosed and paid to other customers? I would think TISA would not allow this, but I can't find anything specific in the statute. We want to do this so as to not lose a large account.