Latest Lending - Fees Topics

Charge Late Fee on a Consumer Single Pay Note?

06/23/2019

Can you charge a late fee on a consumer single pay note?

Lenders Pay/Credit Back Lenders Title Policy

04/14/2019

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.

Membership Notice of Increase in Late Fees

02/24/2019

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.

How to Cure A Loan Post Consummation

10/21/2018

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?

Charging Fees for Credit Reports

09/23/2018

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.

"Life of Loan" Fee for Real Estate Tax Check

09/23/2018

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?

Loan Officer Compensation Question

06/10/2018

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?

HOEPA Consuling Fee-Added as Free Charge?

10/29/2017

When the bank is refinancing a loan and the loan is ​subject to ​H​OEPA, 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 re​scission?

Convenience Fee for Loan Payments Over Phone w/CC

10/22/2017

Can we charge a convenience fee for loan payments made over the phone with a credit/debit card?

Fee for Tri-Merged Credit Report and Application

07/23/2017

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?