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We receive applications for consumer credit (unsecured, auto, etc.) that we decline. As part of that process we obtain with the application a tri-merged credit report at a cost of $20 to the bank. When we decline these applications we don't receive reimbursement of the $20 fee. Can we charge this $20 at application, before obtaining a CBR and before giving a decision on the loan?
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?
A borrower is purchasing a new home. They wish to use temporary financing of a short term interest only loan secured by the old home, to purchase the new home, until the old home is sold and the loan is paid off.Is this a transaction subject to a right to rescind?
Does the BSA officer need to be signing off on money shipments to the bank?
How often should our lenders be completing inspections of construction loan sites? Our policy states that we will complete monthly inspections, however from an efficiency/cost standpoint that seems extreme.
My bank is currently looking into accepting application online. One of the requirements is that the application would need to be e signed so we have a completed application and a signature to pull credit. I am not sure where to start on if we need a new policy for this or what disclosure we would need to provide to our customers.
Appendix D is used for reference in calculating an APR for construction loans. However, it states "Using the 365 payment line, the closest to $251.73 is $253.93 which corresponds to an APR of 11.25%"
What payment line is this referring to and how is this converting to a 11.25 rate; are there books that this is referring to and if so, where can you obtain it?
In my search for guidance on e-Sign compliance for delivery of appraisals (Reg B) and Closing Disclosures (Reg Z) there seems to be a difference in what is recommended for Reg B & Reg Z. All the guidance on delivery of the closing disclosure states that a read or delivery receipt is not a recommended method of documenting proof of the date delivery occurred. However, guidance on Reg B delivery date of the appraisal tends to lean the other way and regarding a read/delivery receipt. In fact the commentary
1002.14(a)(4)(I) even states ... “Delivery occurs three business days after mailing or delivering copies... or when evidence indicates actual receipt by the applicant, whichever is earlier". With the commentary in mind is it necessary for us to get a confirmation e-mail to document the actual date of delivery of the appraisal or can we simply apply the guidance from the commentary and rest on the delivery occurred three business days after xmailing whether snail or electronic mail?
I have been instructed to lead a project around compliance ramifications if negative interest rates were to occur in the US. With regard to deposit accounts, would all TISA and other initial disclosures need to be updated to reflect this change. Since the change in terms would negatively affect our customers. This would be quite an undertaking as we have 10 member banks. Would all of our advertisements have to be re-disclosed? Any feedback is greatly appreciated.
Would a purchase/home renovation draw down line for 6 months then convert to a 240 month term be disclosed the same as a construction to permanent loan since renovations are being made and not construction from the ground up?