hgliii - would you share what webinar this was?

New Anon Sez: Is this discussion applicable to all loan payments? Just consumer? Just consumer secured by a dwelling? I must have missed this rule when it came out.

Also, I'm thinking having a "Reg CC" sign in the lobby does not adequately cover issues regarding payments on loans. Reg CC signs typically refer to "deposits" not all "transactions." A revision may be in order, in our branches.

It's from §1026.36 — Prohibited acts or practices and certain requirements for credit secured by a dwelling.

The webinar was sponsored by NCUA on November 18th "Dodd-Frank Remittances and Mortgage Lending Rules" and presenters were from CFPB. They indicated it would be out on the NCUA wedsite. They had a second webinar on December 18th "Dodd-Frank Act’s mortgage lending rules" and at that time indicated they would be posting both on NCUA Website prior to end of year. I have not found the posting yet.

Does anyone have payment instruction verbiage that's been blessed by their examiners they would be willing to share as an example, pretty please? We've got branches with varying business hours and are struggling to write instructions that adequately cover everything.

*bump*

Payments received prior to 3:00 PM will be credited on the day payment is received, payments received after 3:00 PM will be credited the next business day.

Regulators have reviewed and not criticized our process above, you draw your own conclusion if this amounts to a "blessing" or not.

Be careful about applying early cutoffs to all payment types. Credit card payments are subject to specific payment time frames in Reg Z:

3) In-person payments on credit card accounts. (i) General. Notwithstanding §1026.10(b), payments on a credit card account under an open-end (not home-secured) consumer credit plan made in person at a branch or office of a card issuer that is a financial institution prior to the close of business of that branch or office shall be considered received on the date on which the consumer makes the payment. A card issuer that is a financial institution shall not impose a cut-off time earlier than the close of business for any such payments made in person at any branch or office of the card issuer at which such payments are accepted. Notwithstanding §1026.10(b)(2)(ii), a card issuer may impose a cut-off time earlier than 5 p.m. for such payments, if the close of business of the branch or office is earlier than 5 p.m.