03/04/2002
We are planning a new/used car loan special. The ads will list the interest rate for a new car. What disclosures need to be included in the ad?
01/01/2002
Compliance isn't enough. Consumers need help. You can help them. By helping consumers, you provide better service and make your institution more valuable to the consumer.
12/03/2001
I have many questions as to why the APY is less than the interest on accounts that do not compound and are longer than one year in term. I have tried to explain about rate of return,idle funds, and the fact that APY is annual, etc...but I always get that "deer in the headlights" look. Do you have an easy to understand explanation to this?
11/05/2001
Could someone supply me with the citation in Reg Z which indicates that we must show on our arm tils fed box the different payment streams.For example: 5/l 30 year arm60 months at such and such a payment based on the initial rate300 months at such and such a payment based on the index & margin as of the date of closing.
11/05/2001
With falling rates, we're having several customers who want lower rates on their loans. We're agreeing to do this but charging a 1% (of the outstanding loan balance) modification fee. Does this require redisclosure under Reg Z? We are not refinancing, simply lowering the rate and charging the 1% fee. If we were only lowering the rate, I don't find in Reg Z that redisclosure is required, but the 1% fee would that be a finance charge and therefore, trigger new disclosures?
11/05/2001
With interest rates dropping so low, we are considering lowering rates to zero on some accounts. Since this would make these DDAs effectly noninterest bearing, does this require a 30 day change in terms notification to the customer or will the variable rate change notice in the original account disclosure be sufficient?
11/01/2001
It is always possible to do more than the minimum set by regulation. In the case of Soldiers and Sailors, doing more can be a very good thing.
10/01/2001
Must we notify our customer when interest rates on deposit products are lowered if, at the time the account is opened, we disclose in writing that rates are subject to change at our discretion?
09/01/2001
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06/04/2001
Is it permissible for a National Bank to offer a time-deposit promotion where customers opening that time-deposit would be entered into a drawing with the winner receiving additional (double) interest on their deposit? I have referenced Title 12, Chapter 2, Sec. 25a of the U.S.C., however, I am having difficulty interpreting the Code's definition of a "lottery."