Currently our Rate and APR for the HELOC program are the same on the published rate sheet. This is a variable rate loan product, shouldn't the APR be different taking into consideration the floor and cap on the rate for this type of loan?
Are Appraisal Review fees and environmental report fees considered prepaid finance charges?
What are the consequences if we grant a BSA exemption for a customer who does not regularly engage in large currency transactions (and we know it), then a cash transaction of more than $10,000 occurs, but we do not report it, based on granting that exemption?
We have begun offering GAP (Debt Cancellation Agreement) for auto loans. We are disclosing the cost to comply with Reg Z, however, do we also have to give insurance sale disclosures to the borrowers?
Regulation Z section 226.13 refers to a consumer's credit card or openend credit plan. The commentary makes it sound like the billingerror resolution notice is required for any openend plan but the notice set forth in Appendix G keeps referring to a credit card. Do we need to include the billing error resolution in the initial disclosure and an annual notice for a line of credit where there is no access card? If so, do we just delete the references to the access card and the $50 limit?