Here is our situation, borrowers signed acknowledgment on Reg Z disclosure wishing for life insurance on settlement dated 6-26-01. Loan account entered on computer system 7-2-01.(bank considers this entry as "booking the loan". On 7-23-01 the life insurance application form is filled in/signed by borrowers and mailed to company for approval. Question, according to 3500.17 (g), when does the clock begin counting for the 45 day window? the TIL date 6-26-01, the computer input date 7-2-01, or will it begin on the date the bank receives notice of the approval for the application for insurance coverage? Could you possibly elaborate on the specifics, "when the servicer establishes the escrow account"? Understanding this terminology will help in the future.
Does an attorney fee affect the APR?
What are implications of charging a fee to cover expenses for sending lending documents to closing attorneys by Fed Ex?
If an executive officer has overdraft protection, under 12 CFR 215.4(e) the bank can cover overdrafts of more than $1,000 if we have a written, preauthorized plan. For amounts less than $1,000 do we need a written, preauthorized plan?
Now that the Democrats have taken control of the Senate, the compliance agenda is revitalized. Already topics such as predatory lending and money laundering are on the legislative plate.