08/06/2012
On home equity lines of credit, how far in advance of payments must the billing statements be sent? If a bank chooses to make a change in the number of days must the customer be notified, and if so, how far in advance?
06/11/2012
Is a HELOC that is not tied to a credit card or overdraft account, that is a fixed rate with fixed monthly payments required to have a periodic statement monthly?
06/04/2012
With all things being equal on the GFE (origination charges/credit, everything is the same). 1)Why would an APR be higher on a broker paid comp than a lender comp plan? 2) Again with all things equal (net origination) with the exception of origination/cost credit disclosed for a broker deal but on a banker deal the APR is not the same.
04/02/2012
Can you charge a $10 minimum finance charge on an HPML? The note is written such that there is no prepayment penalty but there is a min. finance charge of $10 - practically speaking, would only be used if customer paid off loan just a couple days from its closing.
03/19/2012
On the new Truth in Lending section under prepayment penalties, are we required under Reg Z to refund a part of the finance charge (like origination) if a loan is paid off early? Is it a state/regulator specific requirement? Or can each individual bank decide if they want to refund or not?
03/12/2012
In talking with The Federal Reserve Board, it was determined that a negative finance charge is not a charge but a credit and should not be used in calculating the APR. We have found a blog on <a href="http://www.bankersonline.com/lending/guru2010/gurus_ldng102510a.html">BankersOnline website</a> that states differently. Where can we find the information to back up the answer that was given on this blog?
02/27/2012
12.5% "finances charge" were added to an auto loan without notifying the customer. There was no contract delivered at time of sale. Is this legal?
07/25/2011
Recently, it was brought to my attention that when we calculated the odd days interest for the APR we were using a 365 day year and our loans were on a 360 day basis (besides the other fees needed for the APR). Is this considered as understated interest so the APR is incorrect?
07/18/2011
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?
07/11/2011
When including PMI insurance based on a monthly premium in the finance charge, how many months of the premium do you include as part of the finance charge?