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Where are Credit Card Rates Disclosed

12/03/2023

Is there any requirement to disclose the specific rates used to calculate purchase, balance transfer, and cash advance APRs in the credit card agreement, if that information is already clearly disclosed with all other required pricing information (as defined in Reg Z 1026.6(b)(2)(i) through (b)(2)(xii))? This is already provided on our Interest Rates and Fees Disclosure form provided to the applicant with the card. For example, our credit card agreement (a separate document from the Interest Rates and Fees Disclosure) includes "For the non-promotional purchase and balance transfer APR, we add X.XX% to the Prime Rate. For the cash advance APR, we add XX.XX% to the Prime Rate. However, all of this information is also disclosed on our Interest Rates and Fees disclosure, which is given to the applicant with the Account Agreement and card.

Pros and Cons of Commercial Loan Apps

11/26/2023

Currently, the bank I am employed by uses commercial loan applications. In my prior work lives, the banks never had a specific cmmercial loan application. Are they required? I realize some compliance related items are collected on them; but believe this could be done in another manner. Thoughts on this topic and why you would recommend keeping them or eliminating them.

Home Loan Toolkit Disclosure Rule

11/19/2023

Is the Home Loan Toolkit required to be given when no address is listed (such as a pre-approval) for a home purchase loan?

HMDA Ag Exemptions

11/19/2023

Our borrower inherited half of her father's farm. We made a loan for her to buy her sister's half. The loan is secured by the farm. Our customer is going to rent out the land and the home. She won't be farming it herself but will be receiving rental income from it. Does this qualify for the agricultural exemption for HMDA?

MLA - Open-end and ODP Coverage

11/12/2023

The Military Lending Act does not specify if the Act applies to an open-ended Overdraft Protection line that is tied to a checking account or a closed-ended loan secured by the applicants’ deposit accounts such as a savings and/or certificate of deposit. Does the Rule apply to both consumer credit types?

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Where are Credit Card Rates Disclosed

12/03/2023

Is there any requirement to disclose the specific rates used to calculate purchase, balance transfer, and cash advance APRs in the credit card agreement, if that information is already clearly disclosed with all other required pricing information (as defined in Reg Z 1026.6(b)(2)(i) through (b)(2)(xii))? This is already provided on our Interest Rates and Fees Disclosure form provided to the applicant with the card. For example, our credit card agreement (a separate document from the Interest Rates and Fees Disclosure) includes "For the non-promotional purchase and balance transfer APR, we add X.XX% to the Prime Rate. For the cash advance APR, we add XX.XX% to the Prime Rate. However, all of this information is also disclosed on our Interest Rates and Fees disclosure, which is given to the applicant with the Account Agreement and card.

Pros and Cons of Commercial Loan Apps

11/26/2023

Currently, the bank I am employed by uses commercial loan applications. In my prior work lives, the banks never had a specific cmmercial loan application. Are they required? I realize some compliance related items are collected on them; but believe this could be done in another manner. Thoughts on this topic and why you would recommend keeping them or eliminating them.

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