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?
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?
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.
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.