We see quite often where lenders agree to pay for or credit back items such as the lenders title policy. This is often done when a lender wants to capture the business of a builder so they offer this as a "perk" to the referrals coming from that builder. I was wondering how other lenders manage to do it without violating any regulations. We wouldn't plan to do this across the board.
We are looking to increase our late fees on our consumer loans (installment and line of credit) not affecting any HELOC or mortgages at the first of the year. I know based on our current disclosures we cannot increase late fees on existing loans but can on the new loans made going forward. I am looking to see if we need to provide our membership with a notice of increase in fees? If so, does it need to be in a newsletter or can it be a hard coded message on the statements? I can't seem to locate this within Reg Z rules.
We recently found a fee that was charged to a borrower and needs to be cured. The closing has already happened and we charged too much. Could you tell me the proper steps on how to cure a loan post consummation and where do we place the cured amount on the cd?
We are looking at charging fees for credit reports. We have never done this. How do we do this correctly? We are looking for any recommendations or guidance you can offer.
Our state pays real estate taxes semi-annually. Can we charge a "life of loan" fee on consumer real estate loans for performing a real estate tax check? If we can charge such a fee, must it be incorporated into the loan origination fee (which we currently do not charge) or can it be a separate line item? If a separate line item, where does it get placed on the LE/CD?
We have an outside team and would like them to refer their customers to our inside team since the outside team has too much to handle. Can we still offer some compensation to the outside team since they are referring their customers to are inside team?
When the bank is refinancing a loan and the loan is subject to HOEPA, the customer has to go to consuling. After the LE is given, the customer comes back and says he cannot afford the $100.00 consuling fee. Can that fee be added as a fee charge or should it be added to the amount requested? If added to the amount requested, does this trigger a right of rescission?
Can we charge a convenience fee for loan payments made over the phone with a credit/debit card?
We receive applications for consumer credit (unsecured, auto, etc.) that we decline. As part of that process we obtain with the application a tri-merged credit report at a cost of $20 to the bank. When we decline these applications we don't receive reimbursement of the $20 fee. Can we charge this $20 at application, before obtaining a CBR and before giving a decision on the loan?
In the event when a joint credit report is pulled for a joint application, but then the loan is restructured using only one of the borrowers and the credit report is unmerged to obtain only the individual borrowers credit data, can the lender collect the charge for both invoices from the borrower (the invoice for the original report and the invoice for the unmerge service)?