Vendor Guru Q&A - Lending

Latest Lending - Credit Life Topics

Insurance Disclosure Required?

07/17/2022

We do not offer credit life insurance on the consumer real estate loans. Are we required to have the customer sign the Federal Sale of Insurance Disclosure at application for these?

Credit Life Sale Disclosure-Signature?

08/16/2020

Our bank sells credit life and offers it to our clients. Is the credit life sale disclosure required to be signed by the applicant. Is there such a disclosure with no signature requrement?

Discontinued Credit Life Insurance for Loans

02/09/2015

We recently stopped offering credit life insurance for our loans. Our Financial Services area does not offer this product either but would offer a term life insurance policy as an alternative. If the customer comes to the loan officer and inquire about insurance, we would refer them to the Financial Services area so that they can shop for term life insurance products. Since we are not offering the credit life insurance product anymore and our Financial Services area doesn't sell it, are we still required to provide the Federal Credit Application Insurance Disclosure to our customers? I would think that we don't need to unless a customer inquires about insurance, then we would need the disclosure to be provided to the customer. What is your opinion on this?

What determines HPML Classification?

03/14/2011

I have a balloon note that has matured. It had credit life. The loan will be renewed with credit life. Is it considered a HPML because we are financing the premiums?

Disclosing Premium Fee on GFE

01/10/2011

Concerning a mortgage loan with voluntary credit life insurance, do I disclose the premium fee on the Good Faith Estimate?

Required Insurance Sales Disclosures

09/06/2010

On our consumer notes we have the credit insurance clause that the customer signs when signing the note, and on the note is also the Federal Sale of Insurance Disclosure that the customer signs if he/she decides to get the Credit Life or Disability Insurance. When printing the documents, it prints the Federal Credit Application Insurance Disclosure. All this is in our software from Arta Lending. If all this information is on the Arta Note, do we have to print and have the customer sign the disclosure also?

VSI on the Purchase of Insurance Disclosure

08/23/2010

We have changed lending software providers. We require VSI insurance on all titled property loans. Our previous software included VSI on the Purchase of Insurance Disclosure; our new vendor does not include this disclosure for VSI purchase, only Credit Life and GAP Insurance Purchases. Should VSI be disclosed on the Purchase of Insurance Disclosure?

Credit Life on Commercial Note

12/07/2009

Is there a reg that specifically states that one must have the Credit Life box to state whether you do or do not want Credit Life on a commercial note?

Reg Z Reimbursement Procedures

04/06/2009

We have some consumer loans where the customer did not sign for credit life insurance so we treated the premium as a prepaid finance charge and completed an APR calculation. Can the reimbursement be credited to their loan or does the reimbursement need to be paid directly to the customer? Is there a time frame after we discover the error and if so, where does it state the time frame in the regulation?

Insurance Disclosures on Business Purpose Loan

07/14/2008

Do we need to provide insurance disclosures to a customer who purchased credit life A/H insurance on a loan with a business related purpose?

Is it OK to charge a monthly Returned Mail fee to customers with bad addresses?

04/17/2024

May we charge a monthly “Returned Mail” fee on our customers who have bad addresses that return mail as undeliverable?

Is the NMLS ID # supposed to go on HELOC documents too?

04/14/2024

Does the NMLS ID# number need to be included on HELOC agreements and Deeds of Trust / Mortgages?

REMA Issues and Advertising

04/14/2024

If all of a lender's marketing is targeted outside the US, aside from marketing within its "claimed" assessment area, could the lender be subject to REMA redlining review? I've read guidance that implies marketing doesn't have to be a factor for a REMA redlining exam to be conducted... • "REMA...defines who and where you serve, and as such, is different from a defined Market Area..." • "Where the lender actually marketed and provided credit, and where it could reasonably be expected to have marketed and provided credit based on its distribution of loans and applications " • Redlining analysis will look at lending and level of services in majority-minority census tracts compared to peers, among other items.

HMDA Reportable Loans?

04/14/2024

Are refinancings of second homes HMDA reportable?

How do I figure out how much Reg Z restitution is needed for an APR / Finance Charge error? It is a TRID loan too. HELP!!

04/14/2024

We messed up an APR beyond Reg Z tolerance (on a TRID loan to boot – eek!) and know we need to give the borrower restitution. But how do we figure out the right amount to give?!

Latest Lending - Credit Life Topics

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