What are some general topics we can expect to see from the CFPB in the coming months?
During the PPP loan programs we had many requests, but we were not participating? These are commercial requests and would be subject to Reg B. Were adverse action notices required?
What are some examples of exceptions due to incomplete information?
If you have an agriculture real estate loan to purchase land with a muti-purpose building with four walls, do you need to do a flood hazard determination?
During a conversion the bank made an error regarding our loans account in the customers favor. These were paying demand deposit accounts which had been overdrawn. We would like to raise the APR to charge the existing customers the correct rate. Since this would have an adverse impact on the customer, we would have to send the notice to all existing customers, at least 60 days in advance. The question would be is there a sample form that we could utilize to send to our existing customers?