Vendor Guru Q&A - Lending

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Advertisement for Finance Offer-Trigger Terms

11/18/2018

I am new to lending compliance and have an advertising question. My bank wants to advertise the following: "Enjoy our special 20-year financing offer. Ask us for details." I am of the opinion that "20 year financing" is a trigger term and therefore requires APR, down payment and repayment terms. My predecessor disagrees because an interest rate is not quoted. Along the same lines, if an advertisement says, "15 and 30 year fixed rate loans available" would we have to disclose rate and payment options for both terms assuming this is a trigger term?

List of Triggering Terms for Open-End Credit

03/25/2018

Is there a complete list of triggering terms for open-end credit (credit cards namely) somewhere? I have scoured the internet and cannot find a definitive list.

Internal Customers-Run FTC Do-Not-Call List?

11/05/2017

If we are calling a current mortgage customer to let them know they may qualify for a lower rate with a refinance, are these internal customers required to be ran through the FTC Do-Not-Call list?

ECOA Requirements for Conditional Approval Letter

01/01/2017

I am trying to find out what the federal regulators would require we have on a Conditional Approval Letter issued to a borrower. Like the FDIC logo, Equal Housing, etc. What does ECOA require be on this letter?

Using the EHL logo

10/23/2016

We include the Equal Housing Lender logo in all our home loan ads. Are we also required to include the “Equal Opportunity Lender” logo?

Compliance Logos for "Finance Provided By" Sign

12/20/2015

Does a mortgage lending officer have to display any compliance logos for a "finance provided by" sign posted in a yard?

Advertising Record Retention Requirements

09/07/2015

What is the current advertising record retention requirements for TILA, RESPA and TIS advertising?

Prequalification Estimate & APR

08/16/2015

What if a consumer is prequalifying for a loan and wants a cost estimate. Since the estimate also contains the loan amount, rate, payment, as well as the fees, (trigger terms) shouldn't it also contain the APR, or is it ok to allow this requirement to slide on the basis that it is similar to giving a real estate office or newspaper your rates?

Equal Housing Lender for Multi-Family Lending

07/26/2015

Our bank offers commercial mortgages as well as mixed use and multi-family lending. Do we need to include Equal Housing Lender and dog house on our advertising and marketing materials for any of these products?

FDIC and Equal Housing Lender Information Relative to Advertising OREO Property

07/12/2015

If we are listing OREO property for sale in the newspaper, must we include the FDIC or Equal Housing Lender information?

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Mortgage Lenders, Social Media, and Advertising

Question: We have a couple of mortgage lenders using their personal Facebook page to talk about Mortgages and receive customer reviews.

APR Paid by Lender-APR Fee from Borrower?

02/17/2019

If an APR fee is paid at closing by the lender should it still count as a APR fee the borrower pays?

Updated Index for Discounted Rate on ARM Product

02/17/2019

We offer a discounted rate with some of our ARM products. We use the index at the time the rate was set to calculate the fully indexed rate throughout the entire loan and that is what is disclosed on the LE and CD. Under what circumstance would we locate an updated index from a the date of closing or within 45 days of closing and disclose a blended APR. Would this be a 2 time construction closing? We disclose based on once the rate/index is locked that is the rate/index we use when we close. Unless of course the loan is re-locked for any reason.

Notice to Commercial Real Estate Purchasers"

02/17/2019

What, if any, is the regulatory cite requiring the lender to provide the borrower a "Notice to Commercial Real Estate Purchasers?" It is related to CERCLA.

CFPB Update On Construction Loans (Perm Financing)

02/17/2019

We are being told that the CFPB has given an update on construction loans at the time of perm financing. We are understanding it to read that if you do the modification into perm financing (no new loan) it is not HMDA reportable. Does this mean a construction loan would never to reported if this is the case?

Savings Acct. as Collateral-Loan Fees

02/17/2019

For a loan with a savings account as collateral, can all of the loan fees (doc fees, credit report fees, etc) be included in the savings hold?

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