Most Popular Lending Content
Fair Lending Policy: Reverse Redlining Issue
07/07/2003
We have utilized a prefab fair lending policy from a nationally known compliance consultant. In this policy it states that "The bank shall devote special attention to the credit needs of the low and moderateincome neighborhoods within its community (as defined in its CRA policy and CRA statement). To the extent possible consistent with safety and soundness, the bank shall make credit available on more favorable terms than it otherwise would offer to residents and owners of small businesses (and small farms) within such low and moderateincome neighborhoods." This was intended to convey CRA efforts. The examiners are looking at it as a violation of REG Breverse redlining. In speaking with the national vendor that wrote this policy, they see nothing wrong with it and several banks across the country use it and have had no problems. What is your opinion and do you know of any written info to back it up?
Industry Averages For Credit Card Charge Offs
07/07/2003
Do you know or know where I can find the industry average for credit card 30+ delinquency and charge-off percentages?
Linking Overdraft Protection To Business DDA Accounts With Automatic Transfers
07/07/2003
Is it possible to link overdraft protection on a Business DDA account with automatic transfers instead of establishing a separate business line of credit with fund transfers?
Perfecting A Security Interest In A Life Insurance Policy
07/07/2003
What are the requirements to perfect a security interest in a life insurance policy? We are going to get an Assignment/Acknowledgment from the insurance company, but do we need to file a UCC-1 on the policy itself?
Disclosure Requirements For Auto Debit Reduced Rate Loans
07/07/2003
If we offer a program of a reduced-rate loan if customer puts the loan payments on auto debit out of a checking or a savings account, what kind of disclosures would we need to give and is there a form available?