Can a bank be liable for encouraging employees to solicit responses to a contest benefitting a local charity with links posted on their personal social media pages?
Can our bank prohibit (or strongly discourage) employees from listing their bank name on their personal Facebook page?
Do you have to display "Member FDIC" on Facebook posts if you are simply saying "Check out this new checking product" and provide readers with a link that takes them to a page with full disclosures?
Our new marketing director believes we have to be on Facebook, Twitter and other social accounts, and believes having employees writing and making the posts will make us more transparent and friendly to our customers. What risks do we face with all-employee access?
Do we have to disclose the actual MAPR to all borrowers?
Can we report a past due loan to the credit bureau when SCRA protections apply?
Does the OCC or other regulatory agencies specifically allow or frown on borrowers taking photos for real estate inspections if the lender requests these through the Verisite Firewall application? The Verisite mobile app can geocode the photos for location confirmation but having the borrower involved may be an issue. Otherwise this could be a way to expedite the processing on some loans.
If a fee is deleted on the closing disclosure in section B and the disclosure was sent out for signing, do we re-disclose to the borrower and show that fee as a Lender Credit?
Does a non-borrowing spouse need to sign or acknowledge the initial Closing Disclosure for a purchase of a TRID loan? Does it matter that we are in Indiana?
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?