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Compliance Calendar
02/01/2001
February
Compliance Calendar
02/01/2001
MarchMarch 9 is the due date for comments on the Federal Reserve Board's proposal to amend Regulation C, HMDA, to increase the information reported on the LAR.
The APR is calculating lower than the rate. Can that be right? -- e-bgroup
01/16/2001
We are currently offering a 5/1 ARM at 5.50% with caps of 2/6. Margin of 2.75 based on 1 yr t-bill. Currently the T-bill is 2.06 therefore using this as an estimate for future payment changes results in the rate lowering with the 61 st payment. This then results in a lower finance charge throughout the life of the loan and therefore calculates an APR that is lower than the rate. Is this correct? I'm not seeing other banks with similar products disclosing a similar APR.Any information you have would be greatly appreciated.
Is Reimbursement Required?
01/15/2001
Concerning Reg Z and the TIL form, when we find that our bank has improperly disclosed the APR and Finance charge on a mortgage loan, how do we go about calculating the reimbursement? Does this always automatically trigger a reimbursement? I have tried to find info on it in the regulation but have not found anything to help.
Directors As Guarantors
01/15/2001
We have a loan request from a company contemplating that one of our outside directors would guarantee the loan. What would be the treatment of the loan under Federal Reserve Regulation O?