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Loan Estimate Not Provided by 3rd Business Day

09/27/2020

There are competing thoughts on the appropriate way to treat an application when the Loan Estimate is not provided by the 3rd business day following the applicant's submission of the six pieces of information. Theory 1 - Cancel the existing application and restart the application process. This may be due to some issues with selling the loan on the secondary market. Theory 2 - Show it cas a "self-identified" issue on the file and continue with the file as is. As long as it is not a pattern in practice and is just a one-off from the established controls, there should be no ramifications. Please help in identified whether #1 or #2 (or may be a 3rd option we aren't thinking of) would be the most appropriate.

How to Resolve 30 Year Residential Loan

08/23/2020

How do we resolve a conventional 30 year residential loan, originally floating at application, that was closed without being officially "locked," at the rate originally stated on the LE, which did state that the rate was floating? Will the resolution differ if the now current market rate has dropped lower than the original stated rate versus an increase in the rate?

Policy on Customers Taking Pics of Records

05/19/2019

Does anyone have any suggestions for putting together a policy on how to handle customers using cell phones to take photos or record interactions within a branch?

Modification on S Consumer Lot Purchase Loan

04/08/2018

This pertains to a loan modification on s consumer lot purchase loan. No new money is lent. We are modifying the maturity date and terms. (1) Can the interest rate be modified? (2) Does TRID apply?

Signs in Lobby for Loan Production Office

09/03/2017

We are going to open a loan production office and need guidance on what types of signs need to be in the lobby. I'm thinking only the Equal Housing Lender Poster, but not sure. We are not taking deposits, and we are not a HMDA reporter.

TRID and the tax service fee

05/29/2016

On a secondary market loan where our loan servicer charges a tax service fee, should that be included in the origination charges section or services you cannot shop for?

Notification when Sending an Account to a Collection Agency

01/17/2016

When we close an account due to overdraft, we mail notices to the customer of the amount owed and that the account should be brought to a positive balance to avoid any collection proceedings. Do we need to mail a notification to the account holder when we have sent the account to a collection agency?

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We Can't See the Forest

A recent investigative report from a newspaper in Sarasota, Florida highlighted the many reasons why banks fail, and they cite unethical lending practices, employee greed and dishonesty as a few of the culprits.

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Chamber of Commerce Cash & Prize Giveaway

10/25/2020

Our Chamber of Commerce is hosting a cash & prize giveaway to encourage people to shop local during the holidays. As a member of the Chamber of Commerce, the bank has been asked to pass out tickets as entries to win. Each business has a limited number of tickets. Employees of the bank are not allowed to obtain any tickets from the bank, but can from other businesses participating. My question is, can we offer multiple tickets as incentives for our customers to use other services we offer? Examples would be: 1) A customer comes in to make a deposit= 1 ticket. If they sign up for online banking while here we will offer an additional ticket. 2) A non customer comes in to cash a check= 1 ticket. If they open an account with us we will offer additional tickets. 3) A customer asks about a home loan= 1 ticket. If they qualify, they can earn additional tickets. If they decide to finance with us more tickets.

Reg E Question About Credit Card Fraud

10/25/2020

When a cardholder has a fraud alert on their card and they tell the fraud center that the transactions are NOT fraud, the fraud center reopens the card. Now the customer has roughly 10 or more charges from the same company that she just said were not fraud. Now she is claiming that they are all fraud. (including the original charges) What do we do?

Misleading Collection Scripts Cost Financial Institution $28.5 Million

10/18/2020

In its $28.5 million settlement with Navy Federal Credit Union (NFCU), the Consumer Financial Protection Bureau (CFPB) stated that NFCU's collection letters contained material misrepresentations – or unfair or deceptive abusive acts or practices – that were likely to mislead consumers; how did NFCU's templates violate UDAAP?

Add Bank Fees Paid in Cash to CTR?

10/18/2020

Should bank fees (Cashier Check purchase fee of $6.00) paid by the customer in cash, be added to their current CTR? If so, would the bank be the benefactor and the customer the transactor?

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