Most Popular Compliance Content
Denied Loans Exempt from Early TILA?
06/30/2008
When a loan is declined within three days of application, the early RESPA disclosures are not required. Are the Reg Z early disclosures required? I can't seem to find anything in the regulation that would exempt denied loans from the early TILA.
Newspaper Loan Closing Coupon - APR & Disclosures
06/30/2008
Our marketing person would like to offer $100 off loan closing costs on mortgages until the end of June with a cutout coupon in the newspaper. Would we have to show this as a POC on the HUD and does it affect the APR?
ACH Debits - Three or Six Limit?
06/30/2008
I wanted to get clarification on whether ACH debits were considered in the three or six limit, so I talked with the Director of Compliance for the Federal Reserve and she told me that ACH counts in the three limit along with checks, drafts, debit cards and similar orders to pay because of the convenience. Is that correct?
Check 21 Substitute Check Policy Disclosure
06/30/2008
We mail a substitute check policy disclosure with any returned deposit checks that are converted to substitute checks. Another financial institution told us they no longer mail them because it is not required. Can we stop this practice and still be in compliance?
Joint Applicants - Separate Adverse Action Notices
06/30/2008
We have been told that when we have a joint application and we deny the credit we have to send separate adverse action notices to each applicant, is this true?