Most Popular Lending Content
Double Interest During Rescission Period
02/02/2004
This question is in relation to Reg Z's right of rescission. On a loan that is subject to right of rescission, we can start to accrue interest as of the date of the loan, not the rescission date. However, if we pay the loan off as of the date the loan comes out of recission, the customer will be paying double interest during that rescission period. Is this allowable?
Altering Collection Notes
02/02/2004
We have a system on which notes on collection activities can be stored. Currently, the system will not allow us to change the notes, not even if we misspell a word. There is talk about having our programmers change this screen to allow a collector to change the notes. Is it against any regulation/ruling to allow collection notes to be changed?
Preemption and Predatory Lending
02/01/2004
The OCC has issued a final rule to preempt state laws that have the effect of limiting the powers of national banks.
Another BSA Enforcement by FRB
02/01/2004
The FRB, together with the Ohio Division of Financial Institutions, has reached a written agreement with the Custar State Bank to resolve deficiencies in compliance with BSA and lending practices.
Disclosures of Fees on Commercial Loans
01/19/2004
Our sister bank was told by their examiners that they were in violation for not disclosing fees such as overnight fees on commercial loans. What fees are required to be disclosed in this instance? We typically list the loan fee and flood fee on the note under Additional Charges. What, when, where should we disclose on a commercial transaction (real estate and non-real estate related)?