New Loan Estimate If IR Is Still The Same?
12/25/2016
If the interest rate is locked at application and the rate is still the same once the rate lock expires, does a new Loan Estimate need sent to the borrower?
12/25/2016
If the interest rate is locked at application and the rate is still the same once the rate lock expires, does a new Loan Estimate need sent to the borrower?
12/25/2016
Can a Financial Institution send out a debit card to an existing customer, even if the current card is not expired? The FI would be sending the new card as a marketing tool, so to someone who hasn't used the card in quite some time. What about if it is a credit card? Same question, but is the answer the same?
12/18/2016
Does Regulation CC apply to savings accounts?
12/04/2016
With a slant toward commercial lending.....I’m trying to find the FDIC guidance on what makes a credit transaction secured versus unsecured. Does it have to be a 1st Trust Deed within the established supervisory guidelines? Can it be a 2nd Trust Deed, but the Combined Loan to Value is still within the guidelines? What if the same bank is already in 1st position and it takes a 2nd on a new loan, but it’s within LTV guidelines, is that secured? I'm trying to find some clarification and/or where I might find the guidance on the FDIC website.
11/27/2016
On a consolidation of student loans, do we need to give the student loan disclosures? The person is no longer a student but working and wants to consolidate their student loans.
11/27/2016
We have a transaction that was primarily for the purchase of real estate for commercial development. There is a single family dwelling on the site that the buyer intends to raze or sell to a buyer willing to have it moved. The loan term is 12 months interest only which may be refinanced for the commercial development phase or may be paid in full. Would you consider HMDA reportable?
11/27/2016
I am a new commercial lender and I am struggling to discover the best ways to prospect for new clients. I usually make cold calls to businesses that I do a little bit of research on and it mostly goes no where. What are things I can do and people I can form relationships with that would cultivate more leads?
11/20/2016
Is there a Reg. O requirement that the related interest reporting for insiders must be completed by January 31st of each year?
11/13/2016
At what point does an oral inquiry for a loan become an application, thereby requiring an adverse action letter if denied? For example: 1. Bob asks about the bank’s car rates and terms for a 5 year old automobile. When he is answered he decides not to proceed. Was this an application that requires an Adverse Action Notice? 2. Sue calls and says she wants to talk about a Home Equity LOC. But the banker explains that it does not offer that loan product. Has Sue applied for a HELOC and required to get an Adverse Action Notice, or was it simply an inquiry that requires no further action by the bank? 3. John says he wants a loan to start up his own business, but mentions he does not have a job currently and filed bankruptcy last year. The loan officer tells John that he won’t be able to help him out. Has John applied for a loan and an Adverse Action notice is required, or did John simply inquire about a loan and no further action is necessary by the bank? 4. Peggy asks for the rate and terms of an automobile loan. The loan officer provides her with the information, then asks how her credit looks. If she tells him it’s not good, and the officer says he wouldn’t be able to make the loan, has Peggy applied and is she due an Adverse Action notice?
11/06/2016
If a consumer lost their ATM/DEBIT card 13 times, are we allowed not to issue another card to the client? Our disclosure only notes a $5.00 fee for replacement cards, there is no limit on replacements.