Is a loan to a company buying stock from an ex-employee CRA reportable? It is secured by business assets.
We had a customer ask to start a voluntary escrow account on an existing loan. Do we need a new agreement?
What is the maximum fee allowed for a NSF check which was returned for a credit card payment? And is there a maximum fee for late charges for credit cards?
When disclosing the payoff of an existing lien on the collateral property, should the amount listed on page 3 of the Closing Disclosure just show the principal balance, or should it show the principal balance, plus the interest due? I do not believe the reg goes into detail on what the amounts listed should be. My thought is we would need to list the amount that would fully payoff that existing lien (principal plus interest). There has been discussions about not capitalizing off interest, but as long as we are not financing the interest due into the new loan amount, I do not see how we would be capitalizing off previous interest. In addition, if we list the payoff as the principal and interest due, would we need to list just want payoff amount, or would we need to list two separate lines on the Closing Disclosure? I believe either way would be okay, but my thoughts are we would just need to list one line item that includes both principal and interest due.
If an MLO transfers to another location at the same institution or there is a change in the address of the location that the MLO directly reports to, how long does the MLO have to update the contact address on the NMLS consumer access site to reflect the (new) accurate address location? I couldn't find anything specific regarding a time frame within the regulation, and it only touched on the requirement of internally auditing, at minimum, annually to ensure accuracy.