We want to offer finacial webinars in Spanish to consumers. These would include smart ways to purchase a vehicle or a home and we have many more topics in mind. Would we need to supply disclosures or other documents in the Spanish if we do this?
A UCC filing fee paid to a government entity to perfect a security interest in a consumer product must be listed in the Fed Box to avoid being a finance charge and included in the APR. Our filing fee is paid to a non-government third party vendor. Because of this third party involvement, our compliance department feels the fee should not be listed in the Fed Box. If all or a portion of filing fee we charge to the borrower will be paid to the government entity I feel that portion should be noted excluded from the finance charge and APR. Do you agree?
What’s the difference between an LOS and commercial loan software?
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.
What are some common types of lending exceptions?