Most Popular Compliance Content
Credit Reduction for Extension of IR Lock
08/18/2019
Regarding a lender credit reduction for an extension of an interest rate lock, may a lender reduce a lender credit to extend the lock period? Example; A rate lock expired 4-25-19 and the closing date was 4-28-19. The initial rate lock and Loan Estimate reflect a lender credit of $2000.00 with 4.25% interest rate. The lock was extended through 4-29-19 at the same rate, but the lender credit was reduced to 1800.00. Since the lender credit was reduced based on an interest rate dependent charge, is this acceptable for interest rate extensions? If it is, is there a requirement that documentation confirms the delay was due to the borrower or outside of the lenders control?
Reg D Apply to Savings Used as Security for Loan?
08/18/2019
Does Reg D apply to a savings account that has been used as security for a loan?
Advertising rates
08/18/2019
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?
UCC Check Presentment-Written/Numeric Amounts
08/11/2019
If we have a check presented for payment and the written/numeric amounts on the check differ, are we allowed to write what we took it for above the numeric amount? At a previous institution that I worked for, we wrote it in red ink, so the proof person would know instantly what we read it as.
Lobby Advertising
08/11/2019
We often have lobby posters advertising products, services, benefits like trips on a discounted price and others things on display so staff can answer questions on these and to promote these items. Do they require the general FDIC advertising statement.
