Vendor Guru Q&A - Compliance

Latest Compliance - TILA Topics

Court Strikes Down Reg Z Finance Charge Exclusion

04/12/2002

by Sam Ott

"Fixed" Doesn't Mean "Fixed Forever"

04/08/2002

by Mary Beth Guard

If the customer increases a loan request, do we need to modify the GFE?

03/11/2002

If a customer applies for a loan secured by residential property and we give them a good faith estimate and they come in a few days later requesting a loan for a larger amount, do we need to give them a revised good faith based on the larger amount?

Finance Charge Violations

10/01/2001

In a R/E transaction (construction loan) if the APR is understated and the finance charge is overstated (due to improperly calculating the estimated interest on the entire balance method) is the violation reimbursable? In reviewing 226.18 and 226.22 it appears that if the finance charge disclosed is greater than the amount required to be disclosed then it is considered accurate and no reimbursement is required. Is this correct?

TIS Obligations and Restitution

01/15/2001

I need a quick summary of our obligations regarding interest recalculation and possible restitution if we discover that we are not paying interest on deposit accounts as disclosed in the Truth in Savings disclosure.

Is Reimbursement Required?

01/15/2001

Concerning Reg Z and the TIL form, when we find that our bank has improperly disclosed the APR and Finance charge on a mortgage loan, how do we go about calculating the reimbursement? Does this always automatically trigger a reimbursement? I have tried to find info on it in the regulation but have not found anything to help.

Question & Answer

11/01/1999

Question: Is there a limit, as an amount or a percentage, that a lender may charge for late fees?

Question & Answer

02/01/1999

Question:: If there is an apparent discrepancy between a regulation and an act, which one should the bank follow?

Are We Headed For A New Compliance World?

10/01/1998

Imagine a world in which banks must give disclosures about their costs and third party costs before the applicant signs or pays anything.

Significant Residential Mortgage Issues for 1999

02/01/1998

by Alan Dombrow, Senior Manager, CFI ProServices, Inc.

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Help from the Bureau: The 2013 HOEPA Rule

Even the Bureau agrees: the list and load of new regulations is daunting. And from our current perspective, implementation seems overwhelming. Fortunately, the Bureau is providing some help.

Foreclosures and Multiple Owners

Question: I have a question related to foreclosures. What are our obligations as a bank to the client before we begin foreclosure proceedings?

Comptroller’s Handbook Series

01/24/2021

How is the Comptroller’s Handbook organized?

Reg E and Tier Three Timely Notification

01/24/2021

Regarding Reg E and tier three timely notification: if a cardholder submits a dispute stating fraud occurred 5/1/20, our institution would apply the tier three timely notification and deny items beyond that statement + 60 days. If that same cardholder comes back after this dispute processes, and claims additional fraud on the same card dating back to 1/1/20, are we allowed under Reg E to re-evaluate that tier three application? Additionally, if the cardholder makes separate claims on two different days (consecutive days for example) is it correct that we may treat that as a single claim?

FDIC Banker Resource Center

01/17/2021

What is the FDIC Banker Resource Center?

Comptroller’s Handbook

01/17/2021

What is the Comptroller’s Handbook?

Availability for Large Check Split b/w Accounts

01/17/2021

If a large not-on-us check was split between a new savings account and an existing checking account, (not the ideal scenario) would you split the availability of the $5,525.00 on the 2nd business day between the two accounts and make the balance available on the 9th business day?

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