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01/13/2019
We are new to auto loan lending and had a general question about allowing credit cards for monthly payments (including our own credit cards). Is this a wise business practice? What is the industry standard for making auto payments via credit cards?
01/13/2019
My institution is beginning an on-line mortgage application process and pre-qualification program. I have some questions with what follow up procedures should be. #1 Individual sees our site and enters a couple of pieces of information, but does not have a completed application. What should be our follow up? #2 The individual completes the application on-line but does not follow up within the 30 days with other required information. Is this an incomplete application? Also, on a prequalification, the individual is notified of being qualified and receives letter stating this online, but does nothing in the allotted time period. Are we required any documentation be sent to applicant? I know this is a lot of questions, but there are so many variables. We are trying to set up our procedures. Any other information in regards to on-line application and pre-qualifications would greatly be appreciated.
01/06/2019
If an individual applies for a loan and they don't qualify, is the lender required to formally disposition (deny) the loan request? Or can they solicit other individuals to be added to the application to see if they would help qualify and get loan approval?
12/30/2018
We have a fixed rate residential mortgage loan borrower. We provided a loan modification of both the rate and payment for 5 years. After this period the rate will return to the higher original rate. Once the 5 year modification term is up, are we required to provide any rate/payment change disclosures under Reg Z?
11/18/2018
I have always been told that if you have a bonefide discount fee (point) that the discount fee does not need to be included in the APR. It seems as if everyone is including in the APR (the discount fee). Is there a way to not include it in the APR?
11/18/2018
I am new to lending compliance and have an advertising question. My bank wants to advertise the following: "Enjoy our special 20-year financing offer. Ask us for details." I am of the opinion that "20 year financing" is a trigger term and therefore requires APR, down payment and repayment terms. My predecessor disagrees because an interest rate is not quoted. Along the same lines, if an advertisement says, "15 and 30 year fixed rate loans available" would we have to disclose rate and payment options for both terms assuming this is a trigger term?
11/11/2018
We have had an internet banking platform for several years and are preparing to roll out the mobile banking interface to internet banking customers. Through both the online platform and the mobile platform, customers are able to access account statements. We currently also provide paper statements to all customers, including those who are enrolled in internet banking. Customers are not able to choose between paper statements and electronic statements in the internet banking platforms (i.e. internet banking customers with access to electronic statements also receive a paper statement). Are we required to be compliant with E-SIGN due to the internet banking customers being able to access account statements electronically, even though they are receiving paper statements?
10/21/2018
We have a farmer who has all of his payments set up to pay annually when the crops are harvested. He is purchasing his primary residence. Can he have this set up on annual payments? I was thinking that all primary residence loans had to be set up on monthly payments?
10/07/2018
We have a customer that has occupied a residence that they are purchasing, and they do not have another residence. Does the right of rescission apply to early occupancy in a purchase transaction? We have gone round and round with differing opinions.
09/23/2018
Our state pays real estate taxes semi-annually. Can we charge a "life of loan" fee on consumer real estate loans for performing a real estate tax check? If we can charge such a fee, must it be incorporated into the loan origination fee (which we currently do not charge) or can it be a separate line item? If a separate line item, where does it get placed on the LE/CD?
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