New Reg Z - Workout Loan
07/12/2010
Do I need to supply an early disclosures/TIL and follow the new Reg Z rules for a matured loan that is considered a workout due to default/delinquencies?
Lucy is Editor of Compliance Action and President of Compliance Resources, Inc., a company offering compliance support and services to banks. She is also a Senior Associate of Paragon Compliance Group, a company dedicated to providing compliance training. She has more than twenty-five years of experience working with regulatory agencies and financial institutions. Her extensive work experience with regulatory agencies includes the Federal Home Loan Bank Board, the Board of Governors of the Federal Reserve System, and the Federal Trade Commission. As the manager of the Compliance Division of the American Bankers Association, she worked directly with several of the association's banker committees and with regulatory agencies to identify compliance priorities, and to produce resources and programs.
You can reach Lucy via email at: griffin@bankersonline.com
07/12/2010
Do I need to supply an early disclosures/TIL and follow the new Reg Z rules for a matured loan that is considered a workout due to default/delinquencies?
07/12/2010
Under the provisions of the Safe Act, do bank loan officers have to be trained and tested, or only fingerprinted and have a background check? I have heard it both ways.
07/12/2010
YSP was not considered APR impacting prior to RESPA Reform (built into the rate). With the change on the GFE to reflect YSP as a credit to the borrower, is this now APR impacting? We think is should be treated the same way it was prior to RESPA reform, but are concerned RESPAs change may have an unintended impact on Regulation Z.
07/12/2010
If there is a negative interim interest (credit) on the HUD-1, shouldn't that be included in the calculation of the finance charge to calculate the APR?
07/12/2010
When a client submits an application for a credit card with our bank, we automatically submit the application for a $5,000 credit limit. Once the application is taken and sent to underwriting and they approve them for a smaller credit limit ($2,000), do we need to issue a Reg B counter offer, and wait for the client approval?
07/05/2010
Will a written policy be required addressing the risk-based pricing regs effective 1/1/11?
07/05/2010
Can a bank provide a customer with three Good Faith Estimates for one loan request? The customer wants a GFE for 95% LTV with PMT, one for 90% LTV in house; and one for 80% with 10/10. The trade off table will not work, since loan amounts are different. After receiving the three estimates, he will decide which one he wants.
06/07/2010
We reviewed our overdraft charges originating from the ATM and one-time debit card transactions, and concluded that we will spend way more on notification, changes and explaining the opt-in for Reg E than we will lose in overdraft fees. Are we required to do anything if we are going to leave all our customers opted out? We won't charge for these transactions; we have already disclosed our fees correctly, so is any action required?
05/03/2010
I received a loan that has a right of rescission violation. The loan was funded at closing and did not wait the rescission period. The officer told me that he will be rewriting this loan to get rid of this violation. Is this okay?
05/03/2010
Is an Early Truth in Lending disclosure required on an owner occupied one-to-four family purchase that includes over twenty-five acres of property?