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?
We have several loan production offices. They don't have cash drawers, are not listed as branches, and they don't service the deposit customer walking in off the street. Do we need signage such as the FDIC stickers? What if a courier for the bank picks up some proof work where only our employees make deposits instead of running to a branch?
I work for an FDIC bank in central Illinois. Some Credit Unions in the area are changing how customers can access their accounts due to a change in Reg. D. Are there changes that should be affecting my bank?
Where in the regulations does it state that a trust (family, corporate, etc.) is not considered a "natural person?"
by Richard R. Bode
We Must Stop the Foreclosure Frenzy
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?
I understand per the Interagency Statement on Retail Sales of NDIP that the referral fee may be a one-time nominal fee paid to the bank employee by either the insurance agency or the bank. If we structure a referral fee so that the first three referrals do not warrant a referral fee and starting with the fourth referral the bank employee receives a fixed amount nominal fee per referral retro-active to the first referral made. Would this be acceptable as a one-time fee?
What loan to deposit ratio would the regulators like to see with regards to CRA?
Is there any regulation preventing a bank from having a lending office only issue cashier's checks without becoming a limited servicing branch?
We are issuing HELOC suspension letters to all customers with LTV ratios of 85% and above. I understand the notification requirements of Reg Z Section 226.9, but do not understand what is required by Reg B Section 202.9. Could you please explain what Section 202.9 would require?