Vendor Guru Q&A - Lending

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Latest Lending - Indirect Lending Topics

Loan Participation Document Automation

12/18/2016

How can we improve the processing of loan participation documents?

Repurchase Agreements

08/07/2016

What are the typical repurchase requirements for early payment default?

AA Notice Required if Counteroffer Not Accepted?

06/10/2013

I know that adverse action notices are required on indirect lending contracts we deny, but are Adverse Action notices required when we submit a counteroffer that is not accepted?

AA Notice if Deny Applicant for Delinquent Credit?

01/28/2013

In an indirect lending situation if you decline an applicant for delinquent credit and the same day the application comes back in with no changes other than the collateral is a subsequent adverse action notice needed?

Car Dealerships - CIP & Due Diligence

06/02/2008

When a bank has an indirect lending relationship with a car dealer, then how does it go about complying with enhanced due diligence, CIP, etc.?

Closed-end Indirect Lending Auto Loans

10/23/2006

A base rate of 9.50% was used for a closed-end Indirect Lending Auto loan. The amount financed in the Schumer box is disclosed as $20,230.55. The note reflects a Loan Processing fee (Prepaid Finance Charge) of $100, but this is not included in the amount financed. The APR in the Schumer box shows 9.68% due to the $100 processing fee. We book the loan on our data processing system as $23,330.55 (amount financed plus the $100) at the base rate of 9.50%. Are we in compliance? If not, is there a tolerance level?

Indirect Lending Statements

09/19/2005

As a credit union, we do indirect loans with dealers. The belief is that it's regulation that we send members with indirect loans a statement at least quarterly. The question is: is there a regulation requiring us to send them statements or could we eliminate this?

Indirect Lending Pricing Question

11/15/2004

Regarding Indirect Lending, is there a maximum mark up rate a lending institution can offer when paying out the spread over the buy rate?

CIP and Indirect Lending

10/06/2003

We are a little confused regarding CIP and Indirect Lending. We do Indirect Lending with a few dealers. They use a generic form for the loan agreement with the loan assigned to the Bank. We have an agreement with the dealer. The loan is not made until the Bank gives approval. Would this be considered a tranfer of assets and no CIP required or the dealer working as our agent?

CIP and Indirect Lending - Lucy Griffin

09/08/2003

CIP and Indirect Lending
by Lucy Griffin, BOL Guru

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Indirect Lending Applications

Question: I have a question regarding indirect lending applications. We require the dealerships to have the customer sign on the application form our institution provides.

Fair Lending: On the Front Burner

Fair lending enforcement is ramping up. Current enforcement efforts are breaking new ground with the consequence that lenders must manage fair lending programs to include these new horizons.

APR Paid by Lender-APR Fee from Borrower?

02/17/2019

If an APR fee is paid at closing by the lender should it still count as a APR fee the borrower pays?

Updated Index for Discounted Rate on ARM Product

02/17/2019

We offer a discounted rate with some of our ARM products. We use the index at the time the rate was set to calculate the fully indexed rate throughout the entire loan and that is what is disclosed on the LE and CD. Under what circumstance would we locate an updated index from a the date of closing or within 45 days of closing and disclose a blended APR. Would this be a 2 time construction closing? We disclose based on once the rate/index is locked that is the rate/index we use when we close. Unless of course the loan is re-locked for any reason.

Notice to Commercial Real Estate Purchasers"

02/17/2019

What, if any, is the regulatory cite requiring the lender to provide the borrower a "Notice to Commercial Real Estate Purchasers?" It is related to CERCLA.

CFPB Update On Construction Loans (Perm Financing)

02/17/2019

We are being told that the CFPB has given an update on construction loans at the time of perm financing. We are understanding it to read that if you do the modification into perm financing (no new loan) it is not HMDA reportable. Does this mean a construction loan would never to reported if this is the case?

Savings Acct. as Collateral-Loan Fees

02/17/2019

For a loan with a savings account as collateral, can all of the loan fees (doc fees, credit report fees, etc) be included in the savings hold?

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