Most Popular Lending Content
Excluding Filing Fees from Finance Charges
12/10/2023
A UCC filing fee paid to a government entity to perfect a security interest in a consumer product must be listed in the Fed Box to avoid being a finance charge and included in the APR. Our filing fee is paid to a non-government third party vendor. Because of this third party involvement, our compliance department feels the fee should not be listed in the Fed Box. If all or a portion of filing fee we charge to the borrower will be paid to the government entity I feel that portion should be noted excluded from the finance charge and APR. Do you agree?
Where are Credit Card Rates Disclosed
12/03/2023
Is there any requirement to disclose the specific rates used to calculate purchase, balance transfer, and cash advance APRs in the credit card agreement, if that information is already clearly disclosed with all other required pricing information (as defined in Reg Z 1026.6(b)(2)(i) through (b)(2)(xii))? This is already provided on our Interest Rates and Fees Disclosure form provided to the applicant with the card. For example, our credit card agreement (a separate document from the Interest Rates and Fees Disclosure) includes "For the non-promotional purchase and balance transfer APR, we add X.XX% to the Prime Rate. For the cash advance APR, we add XX.XX% to the Prime Rate. However, all of this information is also disclosed on our Interest Rates and Fees disclosure, which is given to the applicant with the Account Agreement and card.
Types of Lending Exceptions
12/03/2023
What are some common types of lending exceptions?
The CFPB revoked the HMDA partial exemption in December. Here’s what you need to know now
12/03/2023
My FI has never had HMDA issues before; why do I need this course?
Flood CMPs in 2023
12/03/2023
What has happened to flood penalties in 2023?