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#1702374 - 05/23/12 02:28 PM Loan and LOC Advances
RBanker Offline
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RBanker
Joined: Jul 2003
Posts: 2,675
Austin Texas
DISCLAIMER - my area of compliance oversight is Retail, Operations and OFAC - and this questions strays to the lending side, which I know very little about.

Now, with that out of the way - is there any regulatory reason that we cannot require a customer to have his loan/LOC advances deposited to a bank account at our Financial Institution? (I'm not talking about loan fundings that we wire to title companies, etc.....)

Thanks in advance for thoughtful and/or thought provoking responses.
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General Discussion
#1702449 - 05/23/12 03:41 PM Re: Loan and LOC Advances RBanker
Andy_Z Offline
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Andy_Z
Joined: Oct 2000
Posts: 27,752
On the Net
Reg E addresses repayment via EFTs, but not funding. Since the Tying Act allows deposit and loan accounts to be required, I don't know of any issue.

You could have a UDAAP issue if there is a fee associated with this, such as access to the account, or some other transaction fee. That would be "playing dirty" IMHO. Otherwise, I know of no prohibition.
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AndyZ CRCM
My opinions are not necessarily my employers.
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#1702458 - 05/23/12 03:57 PM Re: Loan and LOC Advances RBanker
RBanker Offline
Power Poster
RBanker
Joined: Jul 2003
Posts: 2,675
Austin Texas
Nope - no transaction fees would be associated - only fees would be transaction type fees - NSF/OD/Wire Transfer/Copies/etc....
No min balance, no monthly s/c......
_________________________
My comments are absolutely no reflection of, nor influenced by, my employer - take them at your own risk.

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