Most Popular Lending Content
APR Tolerance/Redisclosure
02/07/2005
What is the percentage of tolerance for the APR on the initial TIL and the final TIL, assuming the final APR is greater?
Lending against Holding Company Stock
02/07/2005
A bank holding company owns 100% of the bank's stock. Under the Texas Finance Code 34.102, a bank is prohibited from acquiring a lien on its own shares except on an antecedent debt to limit the loss or with approval of the banking commissioner. A bank is allowed to lend against shares of an affiliate per this section. May the bank lend to a shareholder of the holding company stock with the stock as collateral?
Can We Give Customer Copy of Credit Report?
02/07/2005
A customer requested a copy of his credit report and we told him he had to call the credit bureau to request a copy. He said another area bank gave him a copy. Are we allowed to give consumers a copy of their credit reports now? Did something change that I didn't catch?
Acceptable Margin of Error in TIL Disclosure
02/07/2005
We use margin and index calculations to determine rates for ARMs. The index changes every Tuesday and is to be used on loans closed after cutoff that day. If loan documentation is prepared on Tuesday before cutoff time and has an effective date of Wednesday, the previous index is used. In some instances this creates understated finance charge violations according to APRWIN. What type of exceptions, if any, might be granted by examiners in this instance?
No Fee, Waived Fee and RESPA GFE
02/07/2005
Section 3500.7(a)(2) has been cited as the reason that fees must be disclosed even when the borrower is "not likely to incur them in connection with the settlement." Please see 3500.7(a) where it indicates this only needs to be done when the "borrower is likely to incur" them. How do we reconcile the apparent conflict here?