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Our company is wanting to offer Time Deposit accounts. I have read Reg. DD and I see that Time Deposits have certain restrictions on withdrawal periods and penalties but I don't think they are much different than Certificate of Deposits and Auto Save IRA CD's. Basically if we adhere to TISA requirements are we okay to offer these or should I be looking into any other regs or requirements?
I am auditing loan extensions, and I am coming across several loans where the payment the customer makes after the extension is not bumping the next payment due date. I have figured out that this is due to our loan staff not collecting enough accrued interest. So the customer's payment went to interest, not bumping the due date. My question is : When granting an extension, what interest amount should be collected? What is currently accrued and owed at the time of the extension? or like my Bank is doing taking the per diem X the number of days extending? What is the best practice?
Are we required to always follow the E-sign rules when emailing a CD to the borrower 3 days before closing? For instance if we deliver the CD by email (without following E-sign) and the borrower replies that they have received and read the CD, is that sufficient proof that the CD was delivered 3 days before closing? We do not require the borrowers to sign the CD.
We have a customer with whom we charged off a loan and interest accrued. The principal balance is now paid and the customer is paying the interest. Can we charge interest on the interest balance of a charge-off loan?
How can I tell if a loan is cross collateralized, what language shall I look for and in what document?
If we have a Promissory Note that does not state a draw feature, but the Business Loan Agreement does state the draw feature, are we in Compliance? Or would we need to add the verbiage in the Note to be in compliance?
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?
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.
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?
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?