How can we improve the processing of loan participation documents?
What are the typical repurchase requirements for early payment default?
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?
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?
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.?
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?
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?
Regarding Indirect Lending, is there a maximum mark up rate a lending institution can offer when paying out the spread over the buy rate?
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?