Hello BOL World. Happy Tuesday. Hang in there, the weekend is almost here.
Here is the scenario:
A commercial purpose loan was booked for 7.50% a few months ago but the promissory note is actually 8.00%. The bank has decided to throw the customer a bone and keep the rate at 7.50%. Credit wants to know, "what compliance issues does this present and what is needed to document?".
My answer is, because this is not subject to Reg Z and it is to the customers benefit, there are no disclosure requirements other than a memo and possibly a loan modification document.
Does the BOL community concur? For the sake of helping others when they search this topic, let's hear answers for
1.) Commercial (this scenario)
2.) Consumer
Go!
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Maybe you just wanna fly the plane yourself. Well good luck pressing take off, then auto pilot, then land.
CRCM