03/26/2023
If the money is not available in the deceased customer’s account and no estate account exists with the bank, is the bank still liable for reclamations from Treasury?
03/26/2023
Is it required to have a separate "Agreement to Provide Insurance" form signed for non-real estate secured loans? We are in Tennessee and currently have a section in the Security Agreement that prints with the Note which states the borrower agrees to keep the property insured and if they fail to provide insurance, then the bank may place insurance on the property (Creditor-Placed Insurance Notice) and pass that cost to the borrower.
03/26/2023
When a UCC is terminated, then the following year it is continued, then continued a second time, is that a valid perfection?
03/19/2023
On the loan estimate, I input it as a balloon rather than installment which drastically increased the payment. Do I need to redisclose theis with a revised LE or do I make the correction in the closing disclosure?
03/19/2023
We have a board member who sits on the board of a condominium association, but does not receive any compensation to do so by the association. Would making a loan to the condominium association be considered a conflict of interest/Reg O violation? We are thinking not since they are serving on the condo association as a resident (condo owner) in the complex.
03/12/2023
Instead of offering a preferred rate (discount) when auto-payments are set up for a loan, we want to offer instead a discount on doc fee charges. Is there any regulation/issue that would prohibit us from doing this?
03/12/2023
Participation and LIFO Loans
03/05/2023
I have an auditor questioning the timing of the revised Loan Estimate and loan consummation -- I informed auditor that borrower was sent revised Loan Estimate four business days prior to consummation and that is in line with
the regulation; and the 7 business days requirement references the initial loan Estimate (not revisions) --- Am I understanding the regs correctly or not?
03/05/2023
If a lender has a borrower sign loan documents but has some liquidity issues that extend the funding beyond the rescission period, would that be a UDAP violation?
In this example, say the lender expected liquidity to come in from a trade before the rescission was up on the loan. However it was held up for a week. The loan will fund, but a week late. The property is in California if that matters.
02/26/2023
Here is the loan scenario: We have a HELOC for $100,000. Collateral on the loan is rental property. The loan purpose is for home improvement. Our borrower stated that funds will be used as follows:
- $50,000 to do home improvement on rental property, and
- $50,000 will be used for home improvement on their primary residence.
Would this HELOC be considered primarily for business or commercial purposes and why?
