10/18/2010
We qualify loan applicants based on gross income. Our credit officer says that tax free income from SSI or VA Disability is the gross income and shouldn't be grossed up. I say the income is net and should be. Who's right? If we don't gross tax SSI up, are we discriminating?
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?
05/24/2010
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?
08/17/2009
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?
08/10/2009
Where in the regulations does it state that a trust (family, corporate, etc.) is not considered a "natural person?"
07/20/2009
by Richard R. Bode
We Must Stop the Foreclosure Frenzy
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?
04/06/2009
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?
02/23/2009
What loan to deposit ratio would the regulators like to see with regards to CRA?
11/24/2008
Is there any regulation preventing a bank from having a lending office only issue cashier's checks without becoming a limited servicing branch?