On our consumer notes we have the credit insurance clause that the customer signs when signing the note, and on the note is also the Federal Sale of Insurance Disclosure that the customer signs if he/she decides to get the Credit Life or Disability Insurance. When printing the documents, it prints the Federal Credit Application Insurance Disclosure. All this is in our software from Arta Lending. If all this information is on the Arta Note, do we have to print and have the customer sign the disclosure also?
Will a written policy be required addressing the risk-based pricing regs effective 1/1/11?
With the new regs, can the signatures on the early disclosures be dated sometime in the seven day period that is allowed from the application date, if they are mailed to the customer? Sometimes they will be dated after they are received, which is not the application date.
Under new RESPA regs, is it ok to give a preapproval for a home loan with a property to be determined (TBD)?
What changes were made to Regulation DD in 2008? My co-worker said there was an additional one besides the overdraft disclosures that are being required as of 01-01-2010. Is my co-worker correct?
A customer recently purchased a second home, with the intention of it becoming their primary residence after renovating. We did not finance the purchase money, but made the improvement loan. Upon the sale of their current primary residence, they will pay off the improvement loan. The term is one year. The loan officer treated the loan as investment property, stating "not homestead...not subject to RESPA." I find only one sentence in Sec. 3500.5 that would exempt this transaction from RESPA regarding "Any construction loan for new or rehabilitated 1- to 4-family residential property...is subject to this part if its term is for two years or more." Everything else I read indicates that this transaction is subject to RESPA. We are not a HMDA reportable bank, but it also looks like obtaining GMI applies. Can you please advise on both issues?
How do I go about getting new CRA notices for our main bank and branches?
We are looking at implementing E-Statements for business and retail customers but our internet banking provider does not have a method in which to notify the customer that their periodic statement is ready for viewing each month. Is there a regulation that mandates the bank to notify the customer each month (or statement cycle) that the electronic statement is available for viewing?
Are there any regulations that dictate what type of access different individuals such as authorized signers, guarantors, trustees, etc., would have to accounts (particularly via internet banking)?
Are there any federal regulations that govern IOLTAs, IRETAs and funeral trusts? Do individual states have laws that govern these accounts? One of the departments we generally perform compliance testing on for escheat and court blocked accounts accepted responsibilities for these three new areas and we would like to confirm what additional compliance testing needs to be done.