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#1442194 - 09/13/10 08:05 PM Simple Interest Calculation
mstark Offline
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mstark
Joined: Mar 2006
Posts: 336
Bank
We are a thrift institution that uses Harland and Wolters Kluwer. We use the simple interest calculation (365 accrual method) for mortgage loans. Our examiners are stating that if we use this method, it needs to be stated on the note. We have referred them to Reg. Z, 226.8 which does not state that the payment method needs to be on the note. They are saying that is for a bank not a thrift. Does anyone have any experience with this?
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#1442267 - 09/13/10 09:04 PM Re: Simple Interest Calculation mstark
biz Offline
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Joined: Nov 2005
Posts: 1,032
Midwest
We also are a thrift and I've never heard of this, but then maybe that's because we use 360. I find it best to sometimes dummy up and ask if "they would be so kind as to show you where and in what regulation that requirement is required as you have been unable to locate it."

Have you searched their website for note, 360 days, etc? It could be they've issued a TB on it.

Having said that . . .I have always found OTS examiners to be very helpful and it scares the beegeezees out of me as to what the OCC will now be like.

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#1442801 - 09/14/10 06:55 PM Re: Simple Interest Calculation biz
West Coast Comp Offline
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West Coast Comp
Joined: Jun 2010
Posts: 350
Lost in the rain.
Please, have them put in writing that Reg. Z is not for Thrifts so we can stop complying with it. laugh

I've never heard of this "requirement", but we also use 360.
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#1443028 - 09/15/10 01:41 AM Re: Simple Interest Calculation West Coast Comp
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 79,957
Galveston, TX
I think this is one of those "show me" cases, as in show me the regulatory requirement to support the claim.
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