We have been getting conflicting answers on this question. For a personal consumer loan (car, secured, etc), if the customer pays the application fee out of closing (POC), do we deduct it from the amount financed? Example: Customer is getting loan for $2500.00 and she paid the fee herself instead of from proceeds. Would the amount financed be $2500.00 or $2375.00? We have been told to do it both ways. What is the correct way?
We refer customers to an outside vendor for Merchant Services. The company we deal with has created an incentive program for these referrals. They have submitted one of our employees a check in the amount of $50 for a referral that resulted in a sale. I have read and understand the RESPA implications in regards to referrals in the mortgage lending area, but what about the Deposit side of the bank? Do we allow the employee to accept the check?
Our institution wants to increase the late fee on loans from $10.00 to $25.00 (all loans). I know we may change the fee for the new loans but what about the existing loans on our books? Is it possible to change the late fee to existing loans with the required notice advising customers of the change?