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I have identified a couple of loans that have understated APR and Finance Charges. I have run APRWIN, and I am unsure of which amount to use for the reimbursement. These are ARM loans so I'm thinking that I only have to reimburse a lump sum based on the first rate change period. Could you provide some additional information?
Disclosed Amount Financed: $49,393
Disclosed APR: 4.808
Disclosed Finance Charge: $27,468.20
Payment Stream 1: $325.46 for 60 payments with 4 odd-days
Payment Stream 2: $334.61 for 180 payments
What is the guidance for timing of booking a repo vehicle to other assets? Does it have to be at the time the car was taken back? Is it okay to keep as a loan for a few weeks if the car will be sold in that time period?
On a renewal loan (a loan that has matured that is already on the books),. can you finance the unpaid interest that has accrued on the loan you are renewing? What is the answer if you change the loan number and if you don't if there is a difference. I have received conflicting answers on this and would like to know if it is a violation if you roll the unpaid interest in on a note that you are renewing.
I am using APRWIN 6.2 to calculate the APR for a short-term high-interest installment loan.The payment plan spans up to 20 payments which are 14 days apart with different payment amounts. Although an ideal repayment plan is for about 14*20 = 280 days, I see that the APR changes tremendously based on just the difference between origination date and the first payment due date.
First payment period APR
I do not understand why the APR rises by 140% just because the first payment due date changes from 14 to 7 days from the origination date. Is this correct? Is there any documentation which explains the formula being used to understand why the APR is highly weighted on the first payment due date instead of the total repayment period?
We have been asked to collateralize a loan with an independent insurance agents book of business. Since the insurance company owns those policies how do you perfect a book of business? I am looking at this as basically unsecured. Thoughts please.
Does a bank have to charge employees fees on consumer loans?
We have a grocery store customer who is an agent for a large money transmitter. The customer offers no other MSB services and is otherwise not considered an MSB other than being an agent of one for this purpose.
Is there any prohibition to exempting them from CTR reporting? Is it generally acceptable to exempt these agents from CTRs?
Once the principal is paid on a charged off loan, is it best practice to collect the interest first or any fees associated with the charge off?
We have just started with e-statements. Our overdraft protection statements have the same account number as the checking account it is attached to and are created at the same time as checking accounts. Are the Reg E and Z disclosures that we provide with each ODP statement going to be required on every ODP e-statement? Is that also true for the checking statements for Reg E?
If we deny an application for a consumer installment loan from a consumer who applies with a cosigner, do we need to send an adverse action notice to the cosigner?