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Rescission

09/19/2021

Does the Right to Rescind apply to a HELOC?

Differences between the account agreement and the core system

08/29/2021

Our account agreement states that the balance to which the finance charge is applied is determined using the daily balance method. Our core system calculates the balance suing the average daily balance method. Which one is correct?

Electronic Applications

08/22/2021

We receive applications for our home equity lines of credit through our web site. Is it OK to mail the brochure and disclosure after receipt of the completed application?

Electronic Applications

08/22/2021

We receive applications for our home equity lines of credit through our web site. Is it OK to mail the brochure and disclosure after receipt of the completed application?

Electronic Applications

08/22/2021

We receive applications for our home equity lines of credit through our web site. Is it OK to mail the brochure and disclosure after receipt of the completed application?

Line Secured by a Beach House

08/15/2021

Do the Regulation Z rules for Home Equity Lines of Credit apply to lines of credit secured by a consumer’s beach house?

Is a wheel-spin game allowed?

08/15/2021

We have a “spin the wheel” promotion. To spin, a customer must donate $1 that the bank donates to a charity. All the prize amounts on the wheel are more than $1 therefore all customers will get more than they donate. The amount won is then sent to the customer via our e-wallet app. We set a certain number of spins and it is done on a first-come-first-served basis.

Home Equity Application-3 Business Days Rule

08/30/2020

If a home equity loan application is not decisioned within 3 business days and preliminary disclosures are not sent out within those 3 business days, does the application need to be canceled and a new application keyed in? That is our current practice and it's a nightmare for HMDA monitoring submissions.

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Help from the Bureau: The 2013 HOEPA Rule

Even the Bureau agrees: the list and load of new regulations is daunting. And from our current perspective, implementation seems overwhelming. Fortunately, the Bureau is providing some help.

Why Are We Confused?

If you are feeling confused, you are in good company. Almost anyone who deals with mortgage lending compliance is struggling with the changes. Questions are flying. We are surrounded by chaos.

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Requirements to Quote Loan Rates

10/01/2023

When quoting loan rates to customers in person or on the phone, what do tellers/bankers need to say? And ff the banker has an NMLS number, what can they quote and must they state theit NMLS?

Recommended Fair Lending and CRA Software

10/01/2023

We are looking for a good product for recording and analyzing fair lending and CRA compliance. Are there any companies that we should be looking at? We understand BOL and the gurus can’t endorse any one product but would like to know what products the OCC and other regulatory agencies use as that would certainly be of interest. Is there any products not "recommended" but thought of highly?

Reporting counteroffers

10/01/2023

A counteroffer was made, the borrower accepted the counteroffer, and the loan moved forward to closing, but the borrower did not sign the documents at closing and the loan was not originated. Should this application be reported with the original requested values as an Approved Not Accepted, or should we report the counteroffer values as a Denial?

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