We would like to start charging for credit report fees at our financial institution. Are there any fair lending considerations that we should be aware of (especially when pulling joint credit bureaus is concerned)?
We require password changes monthly at our bank. Is there a regulation or guidance that required changes that frequently? I understand more is better, but it is also a huge cost to the bank.
We currently have Home Equity Lines of Credit (open ended) that have floor rates of 6.00% and 7.00% and we would like to reduce these to our new floor rate of 4.25%. I know under Reg Z Section 226.5b (f) it states we can make a change that will unequivocally benefit the consumer throughout the remainder of the plan. With that being said what type of documentation and disclosures must be given in order to stay in compliance with the regulators and terms of the loan? We want to ensure that if we do a modification agreement on the HELOC we do not need to redisclose on the loan.
When doing a Reg. CC review, holding funds for too long or too much constitutes a clear violation. What if, for example, the Notice of Hold was not completed properly (placed big "X" through all reasons as if to say N/A to all, or they simply selected no reasons, or left out the number of days funds would be held). I've received feedback advising these are not violations, just "exceptions/knowledge gaps" and on a review should be listed as such.
Is any part of ADA Website Compliance currently being enforced?
OFAC check for "payer/issuer" of checks deposited by our customers? Do we have to screen against OFAC SDN list?
I unsuccessfully searched for "528.2a". Can you tell me the status of this nondiscrimination regulation? I was interested in the part that says lenders should have available a copy of their lending standards available upon (a consumer's) request.
I was designated and approved by our Board as Compliance Officer in 1999. Our auditors said I need to be reaffirmed/approved by the Board. I'm still the Compliance Officer, nothing has changed. Do you agree?
What method(s) are being used to determine insurable value when calculating the appropriate amount of forced placed insurance?
A title company produces the final HUD-I and there are errors in the comparison chart on page three, but pages one and two are accurate and there are no fee tolerance issues. Is the lender or title agent required to re-disclose any of the HUD-I pages?