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#1403937 - 06/15/10 06:17 PM Re: FRB 3/11 ANPR Reg Z Amend on College Student Loans Valley Girl
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#1415782 - 07/15/10 11:29 PM Re: FRB 3/11 ANPR Reg Z Amend on College Student Loans Valley Girl
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Hello all. I read through this thread and I know a few people have stated this but I'm just curious as to how many people have just taken the stance that their bank will not offer this product. That has been our stance and I'm wondering how much company we have. Thanks!

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#1415880 - 07/16/10 02:03 PM Re: FRB 3/11 ANPR Reg Z Amend on College Student Loans Confused Banker
rlcarey Online
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Most, if not all of my clients have quit.
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#1415963 - 07/16/10 03:28 PM Re: FRB 3/11 ANPR Reg Z Amend on College Student Loans rlcarey
Confused Banker Offline
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Good to know, thanks. We rarely get requests for this purpose in (we don't do a lot of consumer purpose lending) so we did our best on the first two that we did receive. It is just too labor intensive to be profitable but I just wanted to make sure we were not the only ones who came to that conclusion.

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#1416057 - 07/16/10 05:33 PM Re: FRB 3/11 ANPR Reg Z Amend on College Student Loans Confused Banker
swiggles Offline
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Yesterday, we had a loan request for a loan to pay tuition to a firefighter's academy. Thankfully, the applicants changed their minds in favor of a refrigerator purchase. ;o)
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#1416318 - 07/16/10 09:11 PM Re: FRB 3/11 ANPR Reg Z Amend on College Student Loans Confused Banker
ccman Offline
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We quit. With the passage of the "financial reform" bill job security never felt so good.

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#1422545 - 08/01/10 05:05 PM Re: FRB 3/11 ANPR Reg Z Amend on College Student Loans rlcarey
Princess Romeo Offline

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Originally Posted By: rlcarey
Most, if not all of my clients have quit.

Same here - except those credit unions that use "open-end" LoanLiner.
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#1426525 - 08/10/10 03:12 PM Re: FRB 3/11 ANPR Reg Z Amend on College Student Loans Princess Romeo
illiniyak Offline
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I've read through the thread and have still yet to find a solid answer.

We are no longer offering any types of PEL unless secured by real estate or open-end; but we have a loan we made 5 years ago, secured by stock, that is up for renewal in a few days.

If it is just a renewal/extension do we need to do any of the disclosures?

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#1426574 - 08/10/10 03:34 PM Re: FRB 3/11 ANPR Reg Z Amend on College Student Loans illiniyak
rlcarey Online
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#1426577 - 08/10/10 03:35 PM Re: FRB 3/11 ANPR Reg Z Amend on College Student Loans rlcarey
illiniyak Offline
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Thank you

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#1426859 - 08/10/10 07:37 PM Re: FRB 3/11 ANPR Reg Z Amend on College Student Loans swiggles
PStateBank Offline
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Originally Posted By: swiggles
Yesterday, we had a loan request for a loan to pay tuition to a firefighter's academy. Thankfully, the applicants changed their minds in favor of a refrigerator purchase. ;o)


Funny thing, that seems to be happening here also...


We quit making these loans as well. We politely tell the customer we are no longer able to make these types of loans. Please feel free to write their local representatives.
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#1427059 - 08/10/10 11:40 PM Re: FRB 3/11 ANPR Reg Z Amend on College Student Loans MotherCompliance
Duke Offline
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North Eastern CA
We offer collateral loans at this point, tied to a savings or CD account. Would these secured loans fall under this reg z college student loan requirements? The customers do not have to apply for these loans, as it is their money. We do not record the reason for the loan, nor do we ask. We do have them sign a standard consumer loan agreement where they pledge their accounts as collateral.

Thanks,

Duke

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#1427090 - 08/11/10 12:24 PM Re: FRB 3/11 ANPR Reg Z Amend on College Student Loans Duke
rlcarey Online
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Yes they are covered as collateral has no bearing unless secured by real property. If any of these loans to which you speak are for $10,000 or more, not asking the purpose of the loan violates the BSA regulations:

Sec. 103.33 Records to be made and retained by financial institutions

Each financial institution shall retain either the original or a microfilm or other copy or reproduction of each of the following:

(a) A record of each extension of credit in an amount in excess of $10,000, except an extension of credit secured by an interest in real property, which record shall contain the name and address of the person to whom the extension of credit is made, the amount thereof, the nature or purpose thereof, and the date thereof;
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#1434551 - 08/26/10 02:56 PM Re: FRB 3/11 ANPR Reg Z Amend on College Student Loans rlcarey
lucyc Offline
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I just discovered we have some loans that qualify as PEL.

Are there any options to cure since we didn't disclose properly?

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#1434735 - 08/26/10 05:09 PM Re: FRB 3/11 ANPR Reg Z Amend on College Student Loans lucyc
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Bump

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#1434970 - 08/26/10 07:36 PM Re: FRB 3/11 ANPR Reg Z Amend on College Student Loans lucyc
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Bump Bump

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#1435001 - 08/26/10 08:00 PM Re: FRB 3/11 ANPR Reg Z Amend on College Student Loans lucyc
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Illinois
I'm not sure how you can fix it at this point, other than to properly disclose it now. The troubling issue is that they have the right to cancel without penalty up to three days after receiving the disclosures.

Are you sure they weren't just buying a refrigerator?
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#1435257 - 08/27/10 12:25 PM Re: FRB 3/11 ANPR Reg Z Amend on College Student Loans MyBrainHurts
lucyc Offline
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Unfortunately yes I'm sure.

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#1435448 - 08/27/10 03:03 PM Re: FRB 3/11 ANPR Reg Z Amend on College Student Loans lucyc
lucyc Offline
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If the loan has a fixed rate 7% and the default rate is 18% do we need to disclose the default rate as the maximum possible rate?

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#1462273 - 11/02/10 12:22 PM Re: FRB 3/11 ANPR Reg Z Amend on College Student Loans FABCompliance
perplexed1 Offline
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Could you email a copy of the application disclosure?

marybrit.milwee@bankofharlan.com

Thanks,

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#1462679 - 11/02/10 07:17 PM Re: FRB 3/11 ANPR Reg Z Amend on College Student Loans perplexed1
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Are we required, or permitted, to redisclose an approval disclosure that has been accepted based on a change made by the school? For example, the school changes the number of disbursements or the expected graduation date. Disbursement date changes seem to be discussed in the commentary, but other scenarios in which the school could make a change do not seemt o be addressed. Thanks!

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#1498772 - 01/21/11 08:32 PM Re: FRB 3/11 ANPR Reg Z Amend on College Student Loans goingtoexperts
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I am also curious about the maximum rate when you have a fixed rate loan. If it is fixed rate then is the default rate of 18% disclosed or our state's maximum which is 21%?

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