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#2252194 - 04/12/21 01:55 PM Demand Deposit Loans - Incorrect APR Being charged
Bruce Gollop Offline
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Joined: Apr 2021
Posts: 21
Our bank during a conversion made an error in our APR being charged our customers in the customers favor. We would like to send out a notice to the customers informing them of the correct APR. Since this change would have an adverse effect on the customer, we have to send a notice to the customer at least 60 days prior to the APR increase, notifying them of this increase. Would anyone be aware of a sample notice that we can send our existing customers that would notify them of this increase? Thank you

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Lending Compliance
#2252231 - 04/12/21 06:17 PM Re: Demand Deposit Loans - Incorrect APR Being charged Bruce Gollop
Dan Persfull Offline
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Dan Persfull
Joined: Aug 2002
Posts: 47,517
Bloomington, IN
I would advise consulting with the bank's attorney.
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The opinions expressed are mine and they are not to be taken as legal advice.

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#2252261 - 04/12/21 09:40 PM Re: Demand Deposit Loans - Incorrect APR Being charged Bruce Gollop
Richard Insley Offline
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Richard Insley
Joined: Oct 2000
Posts: 10,179
Toano, VA
What you describe is not a regulatory event, but rather a breach of your contract with the borrower. Matters relating to performance of duties under the terms of contracts are subject to state law. As Dan advises, request and follow the advice of the bank's attorney.
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