Most Popular Lending Content
RESPA & Fees For Non-Escrow For Taxes And Insurance
07/15/2002
At the bank I work at we are going to begin charging a fee to our real estate customers that do not escrow for their taxes and insurance. This will be a one time fee when the loan is set up. Is this permissible under RESPA?
Applying Principal To Loans Against A Credit Card
07/15/2002
What are the regulations concerning the application of the principal portion of a payment when the loan is against a credit card that has different balances kept for purchase advances, cash advances and balance transfers? Is it permissible to reduce only one of these balances with the principal portion of the payment or must each balance be reduced? If each balance must be reduced, what is the formula used to decide what portion of the principal is applied to each balance?
APR matrix For Fees
07/15/2002
Is there a matrix out there (Mary Beth probably has one!) that charts APR issues like if a fee falls into what category: fee, finance charge, and prepaid finance charge, or exempt/excluded? I tried to sit down with Reg Z and make one for our bankneedless to say, I am now emailing you.
RA9, Continuation, And The Need For An Initial Filing Statement
07/15/2002
I noted on your Roadmap that you indicated a transaction subject to RA9, with security interested perfected under old A9, perfected by filing, in the correct state, with the correct filing, should be continued prior to the normal lapse date by an initial financing statement. I was under the impression that a correctly filed security interest subject to a UCC1 filing under old A9 that meets all the requirements of RA9 should be continued by virtue of a UCC-3 continuation within the window period prior to the normal lapse date, not by an initial filing statement. Please clarify the need for an initial filing statement. Up to this point, I had understood that the initial filing statement was the means to maintain your lien position at the same time you were "correcting" or bringing into compliance with RA9 a filing not meeting the requirements of RA9, but for which you had been perfected under prior A9.
Reg Z & Interior Billboard Promotion Requirements
07/15/2002
I am reviewing an interior billboard promotion for a home equity credit line and I've looked everywhere in Reg. Z (is that possible?)for the answer to this: The ONLY print copy in the ad reads, "x% less than Prime (for the life of the loan) Ask about our Home Equity Credit Line." Is this ambiguous enough to avoid all the implicit terms disclosures required under 226.16(b), namely, from 226.6?