ATM Disclosures Regarding Fees And Availability
08/18/2003
What is the verbiage required to be posted/disclosed on an ATM regarding fee notice and funds availability?
08/18/2003
What is the verbiage required to be posted/disclosed on an ATM regarding fee notice and funds availability?
08/18/2003
We would like to code our customer file that we use for marketing purposes with an ethnic/race code. This is for marketing purposes only, specifically to track or efforts in reaching out with products to various minority groups. This file information is not generally available to employees outside of marketing. Certainly, not to the lenders. We are concerned about discrimination regulations. Assuming that we do not use this information to discriminate against any particular group and this information is not used in any credit decision, are we OK in doing this? Where can I look for additional help on this matter?
08/18/2003
Our institution would like to charge a one-time $ 75 fee to our mortgage customers for our service of monitoring whether or not their property taxes are paid over the life of their loan. Is this a pre-paid finance charge? Are there other compliance issues we should be addressing?
08/18/2003
We have a customer who is purchasing a condo for investment purpose and is requesting line of credit secured by the condo which will be advanced for the purchase money. Can we do a purchase money open end line of credit?
08/18/2003
We charge a rate lock fee, which if the borrower closes within the initial rate lock period, is refunded at closing. We include the fee as a prepaid finance charge on the initial TIL but should we exclude it from the final since it's refunded at closing. Is this correct?
08/18/2003
Regarding premiums for private mortgage insurance, if the bank is disclosing on the Settlement Statement the monthly premium on a line between 10001008, must the bank also disclose the total payment on line 902 since there is nothing due at time of closing? Payment is paid monthly and there is nothing collected at closing.
08/18/2003
If a bank makes a loan subject to HOEPA without proper disclosures, how can the bank cure the violation?
08/18/2003
The CIP ruling did not specifically address the mortgage lenders. How can we or when should we identify customers on mail applications, telephone applications or when the loan is being handled by a representative with a power of attorney and the borrower cannot be present?
08/11/2003
When we are converting a construction loan on a primary residence to permanent financing, we sometimes advance additional funds to the borrower. If the additional funds are not for construction costs, would the additional amount dispersed be subject to the right of rescission?
08/11/2003
We are providing the financing on mobile homes and the originator serves the loan. Who is required to record the transaction on the HMDA LAR? are providing the financing on mobile homes and the originator serves the loan. Who is required to record the transaction on the HMDA LAR?