Our marketing department brought up the idea of handing out $50 coupons to our customers to entice them to refer folks to get a mortgage loan with the bank. The idea is that if a customer refers someone for a mortgage loan and it closes, the customer can redeem the $50 coupon for cash. I reviewed 1026.36 but it only seems to cover MLO compensation. RESPA's 1024.14(b) seems most applicable but i'm not sure if that just pertains to the parties involved in the transaction. This would be a referral for our customer who told someone to get a mortgage with us.
Are there any regulations on a $50 referral ‘bonus/compensation’ to our customer for referring someone to one of our MLO’s to close a mortgage? It seems similar to what the big banks do with something like a $200 bonus to open an account with them.
Posts on the bank's social media (Facebook) that mention "our residential lending team" but include no mention of rates, terms, etc., do we need to include our NMLS number and EHL logos?
When quoting loan rates to customers in person or on the phone, what do tellers/bankers need to say? And ff the banker has an NMLS number, what can they quote and must they state theit NMLS?
Is it acceptable to run an ad or share a flyer in a foreign language, but not provide applications or disclosures in the foreign language?
For example, we have a Spanish-speaking lender who attends sessions hosted by area non-profits. The sessions are in Spanish, but the flyer he provides is in English. It would be more appropriate if the flyer were in Spanish, although we are not prepared at this point to provide Mortgage applications or disclosures in Spanish.
Our Mortgage Loan Originator's want to hold a drawing at a local high school for a $20 back pack. Since the entries are from students under the age of 18, what do we need to require? Will we need parental permission to enter the drawing or only for the winner to claim the prize?
We often have lobby posters advertising products, services, benefits like trips on a discounted price and others things on display so staff can answer questions on these and to promote these items. Do they require the general FDIC advertising statement>
If we have a rate sheet that we give to real estate agents and our loan originators, but we know the true use will be for them to hand it to consumers or post it where consumers can readily access it, wouldn't we need to have the APR on it?
We have a home equity application disclosure that has a lower Annual Percentage Rate stated than it should be. The disclosures shows in error 4.0% in the minimum payment requirements paragraph where it should be 8.25%.
Is this something that we can fix or is this a rate we must now live with?
How are regulations that are not the fair housing act, fair lending regulations?
On Home Equity Line of Credit statements, is it required or acceptable to include the FDIC and Equal Housing Lender logos for notices and statements?