Bio:
Dan is Vice President and Compliance Officer for The Peoples State Bank with its main office located in Ellettsville, IN and supporting nine branches in surrounding communities. The bank is a privately owned bank that began its existence in 1904.
Dan entered the financial services arena in 1974 when he went to work for Commercial Credit Corporation. He worked eighteen years with Bank One and three years with the Indiana University Employees Federal Credit Union. In addition to serving as a Compliance Officer, he has served as a Collection Officer, Consumer Loan Officer, Commercial Loan Officer and Loan Operations Officer. His primary duties falls within lending compliance, training and consumer loan reviews.
He attended Three Rivers Junior College in Poplar Bluff, MO and Arkansas State University in Jonesboro, AR. He is also a graduate of the ABA Bank Card School, ABA Commercial Lending School and ABA National Truth-in-Lending Compliance School.
Questions Answered
05/23/2005
I am trying to get a question answered related to HELOCs that have attached credit cards. Are these plans excluded from the requirements under 226.5a? We currently have Home Equity Visa Lines of Credit and are looking to do a direct mail promotion where we have a balance transfer option for a 6 mos period at a lower rate. My question is, can we disclose the different rates for purchases, cash advances, balance transfers, etc., in our HELOC disclosures, or must we have a separate disclosure in a "tabular" format, like we would on our normal direct mail solicitations for a regular credit card product?
05/23/2005
I have a retail manager who wants to give a .25% discount on loans to customers who get credit life insurance. For the last several years I have been under the impression that when credit insurance is involved, you cannot give a discount, but I can’t find this stated in any regulation. Do you know if this can be done?
05/23/2005
Is it a RESPA violation for mortgage brokerage firms to offer gifts such as a vacation package to real estate agents in exchange for home loan referrals?
05/23/2005
I would like to offer a promotion for realtors. I would like to prepare an open house flyer for the realtors' open houses. Each time I prepare an open house, the realtor's name is entered into a drawing for $100 of gas. Not tied to me getting the loan. Is this OK?
05/23/2005
What are the benefits of refinancing a mortgage, with respect to getting some cash, in the form of line of credit or equity?
05/23/2005
I have a customer that enlisted after obtaining a loan from our financial institution. She has provided orders from the Department of the Army which reads "You will proceed on permanent change of station as shown." I am confused as to whether this constitutes a "call to active duty." She is asking us to reduce her interest rate and payment amount. Please clarify this for me as to what is "a call to active duty."
05/23/2005
The question was previously asked "Does a Good Faith Estimate need to be provided if a loan is closed within 3 days of application?" Guru David Dickinson replied "Yes. There is no exemption from the GFE requirement if the loan closed early." Our Compliance Officer states this is not accurate; if closed or denied within 3 days no GFE needs to be given.Who is correct?
05/23/2005
Could you please tell me the criteria for the estimated truth in lending and good faith estimate and when it is required and when it is not?
05/23/2005
I am inquiring about the Notice of Right to Receive an Appraisal. Does this apply to Residential Real Estate only? Does it have to be principal residence?
05/23/2005
I'm confused regarding FACT Act Section 212c Disclosure of Credit Scores by a Lender. Volume 8, Number 15 of ComplianceAction indicated that lenders must disclose credit scores for any closed-end loan or HELOC for consumer purpose. Loans for a business purpose would not need the disclosure sent. Based on the above, we would not send a disclosure to the individual who applies for a loan to purchase a 1-4 family investment property. The loan is for business purposes and the borrower signs a document stating that. However, at a recent tele-conference, I was told that we should still send the disclosure because a consumer report was pulled and it's a 1-4 family. What are your thoughts?
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