We have been advised by the OCC to create a checklist for Reg Z for our lenders. Does anyone have a sample that our bank could use as a guide? We would like to get this implemented and added to the bottem of our underwriting worksheet. Thanks.

I'm uncertain as to what exactly you're after, but you can create one fairly easily. Start with your regulators exam questions or go through the reg extracting exactly what you want. That is how I created my audit workpapers.

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Andy Zavoina
Opinions stated are not necessarily that of my employer.

What the checklist should include probably depends on what problems the examiners identified. The most common type of checklist is a loan documentation checklist, which includes much more than simply Regulation Z concerns.

As for only Z, there are two types of checklists that I use when I teach the regulation. One is a list of disclosures that identifies what must be disclosed and what is only disclosed if it is a feature of the contract. It is also sometimes useful to identify what disclosures must go inside the federal box.

The second checklist is always bank-specific. I ask the lenders to list every charge and fee they have ever imposed, seen, or heard of. Then I identify which of those are finance charges for the types of loans. The lenders must include any fee that falls in the finance charge column. It's a good way to keep lenders alert.

Bankers Compliance Consulting (BCC) has developed one of the best checklists for knowing what disclosures to give and when to give them. All of our lending staff and support personnel have a copy on their desks at all times.

Drop Dave at BCC an email. I'm sure he'd share it with you.

ddickinson@hamilton.net

Thanks for the compliment Trent. I'm glad that the checklist can be of use to you and your staff. We call it our Real Estat Matrix. It includes a grid of when you have to give what and when you have to give the disclosures.

I was out of the office today teaching a seminar and when I retrieved my email I had over 15 requests for the matrix. I do not wish to be self promoting, but I thought it would be easier (especially for me!) if I can respond to everyone else by telling everyone how to get their own copy.

Simply visit our website at www.bankerscompliance.com and click on "downloads" from the left hand ribbon. From this page you will see our Real Estate Matrix version 5.3 as well as several monthly newsletters. Help yourself!

[This message has been edited by David Dickinson (edited 10-18-2001).]

Freebies make a community banker's heart go pitter pat. Thanks.

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Andy Zavoina
Opinions stated are not necessarily that of my employer.

Ditto on the freebies
David, went to your website. Terrific!

A few years ago, Alan Dombrow spoke on Reg. Z at a Maryland Banker's conference, and gave us a finance charge checklist that we have found to be very helpful We have tried to scan it into the computer, but have not been successful We are trying to reach Alan to see if we can get this in a Word format. I don't know if this is the type of information you are seeking, but if we get it I will be glad to share.
Leslie

I have an audit form that I have made. I have one for real estate and personal loans that may help you. It is in excell format. I will be glad to share it with you if you will send me your email address.

I will be out of the office till Nov 1....so I can send it then if you want.

According to the Matrix, a mobile home without land would still require an appraisal disclosure. Is this correct? I thought without the land, it was treated like an auto using the book value and title of the mobile home. Am I wrong and if so, where do I learn more about it? thanks for your help.

Every time I look at one thing, a dozen more questions pop up.

Never mind, I found my own answer. In the reg it states to give an appraisal.

I am assuming in the situation where a "bookvalue" is used, we would be required to give that figure since an actual appraiser did not go to the location of the collateral.

[This message has been edited by Maria (edited 10-17-2001).]

Maria:
Section 202.5a(c) of Rg B states the appraisal disclosure or a copy of the appraisal
Must be provided to all applicants for loans to be secured by 1-4 family dwellings. As you discovered it does not matter what the purpose or whether land is or is not involved. Ask yourself "is there a 1-4 family dwelling securing this loan?" If so, comply.

Second, from the commentary to this section:
The term “appraisal report” does not cover all documents relating to the value of the applicant’s property. Examples of reports not covered are:
a) Internal documents, if a third-party appraisal report was used to establish the value of the property.
b) Governmental agency statements of appraisal value.
c) Valuations' lists that are publicly available (such as published sales prices or mortgage amounts, tax assessments, and retail price ranges) and valuations such as manufacturers’ invoices for mobile homes.

Thank you so much. I learn soooo much from you guys!

[This message has been edited by Maria (edited 10-18-2001).]

Leslie: I'm not certain that this is what you mentionned, but the OCC has a Finance Charge flowchart that is helpful. Here is a link to the OCC Compliance Handbook on TIL. The Finance Charge chart is in the Appendix on page 98.
http://www.occ.treas.gov/handbook/til.pdf

[This message has been edited by David Dickinson (edited 10-18-2001).]