07/03/2006
We have a customer who wants us to comply with the Servicemembers Civil Relief Act. I understand we have to drop the interest rate on the loan to 6% when called to active duty. They have sent us a copy of their orders but, from what I can tell they are just a change of duty order. They are enlisted in the Navy, and they feel we should make the rate retroactive to the date they entered the service, are they correct?
04/10/2006
This question is concerning the truth in savings disclosures at account openings. One of the affiliate banks I work with omitted, in error, the interest rate schedule section of the TISA new account disclosure from the time of conversion as a new affiliate of a bank holding company, until recently when it was discovered as an omission. The TISA has since been revised to include the interest rate schedule for the new accounts, however, new account holders for the past 7 months did not receive rate information at the time of new account opening for NOW, Savings and MMAs. Should the bank send out the revised account disclosures to all of the account holders who did not receive interest information at account opening for the last 7 months, or is the fact that these customers have since received periodic statements sufficient?
03/06/2006
On a promissory note is the size of the print on the note required to be a certain size? If so, where would I find the Reg on this?
12/01/2005
Failures in lending compliance can cost as much as $14,000,000. That's the amount one lender will have to pay for unfair lending practices and compliance failures.
10/17/2005
Historically when a customer has called to request interest rates, we have always stated the interest rate immediately followed by the yield. Recently it came up that we may want to state the yield first. I know that the yield must be stated but is there anything that says specifically that the APY has to come first or second? If so, could you tell me where I could find that information?
09/01/2005
Have you ever gone back and looked at a law or regulation when it was just adopted and then compared it to today's version? Take CRA for example.
09/01/2005
Several years ago, HUD published a proposal to revise the Good Faith Estimate required by RESPA. The proposed changes were significant.
08/29/2005
Must we still comply with RESPA requirements for a GFE and Settlement Statement for a fixed rate second mortgage, even if our note and disclosure statement shows finance charges, interest rate, term, etc.? We do not charge any fees, they are all POC.
07/18/2005
Reg. DD's CD APY formula calculates based on 365 days. Is it possible to also use 360 days? Appendix A part 1A seems to suggest that there are options other than 365 days, but we are having a hard time clarifying its meaning. The OCC calculator allows for both 360 or 365 days so that is adding to our confusion.
07/04/2005
Can county and federal funds have a money market account and is there any regulations on the interest rate you can pay them?