03/10/2024
If our bank does not offer a rate lock program and all of our loans are fixed rate loans, can a buyer purchase discount points to lower the interest rate? If they can, do they have to sign a form reflecting the discount rate or can we just disclose the discount and fee on the loan estimate?
12/31/2023
The initial and locked Loan Estimate (LE) on an ARM loan was based off the WSJP index. When it was time to issue the initial Closing Disclosure (CD), the WSJP index had increased causing the APR on the CD to be about 1/2% higher than on the last LE. Should we adjust the index value on the CD to match the index value used on the LE to keep the APR within tolerance, or do we need to update the index value to the current value and redisclose the LE and then inssue an initial CD?
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.
09/24/2023
Are we able to have a floor interest rate on home loans? Is there any regulation on this?
06/18/2023
We have a home equity application disclosure that has a lower Annual Percentage Rate stated than it should be. The disclosures shows in error 4.0% in the minimum payment requirements paragraph where it should be 8.25%.
Is this something that we can fix or is this a rate we must now live with?
05/15/2022
Do you need to modify or prepare a change in terms on a commercial loan when lowering the interest rate but not changing the maturity date? Can it just be done with a maintenance request?
02/06/2022
What regulation dictates the interest basis for a second mortgage?
01/16/2022
I have a question pertaining to an existing ARM loan that is currently tied to LIBOR. For this particular loan the rate adjustment period is annually in April understand that LIBOR will no longer be available after December 31, 2021, but can the bank wait to adjust the index until April 2022?
05/30/2021
If an interest rate adjustment occurs on the mortgage at the same time escrow analysis is completed, can these notices be combined?
Should the payment change date on the table for the Interest Rate Adjustment reflect the payment change for escrow analysis if that date is before the date the payment changes for the interest rate? Ex. Rate changes May 1st. Payment would change June 1st, but the payment also changes May 1st for escrow analysis. The table shows payment change for May 1st.
03/22/2020
When it comes to auto loan rates, we have certain rate discounts that may apply based on an "Engagement Score" for each person. This is determined by our underwriting team and communicated to the dealer for the best rate available at the time the deal is happening so that the correct rate is listed on the contract. The problem is after 5pm when our underwriters go home, we are still getting deals since dealerships are open later. The next day we have a contract signed for the rate the customer qualified for but does not include any engagement score discount.
My question is:
After booking the loan at the rate listed on the contract, may we then adjust the rate down to include the engagement score discount the customer should have received without having to ask the member to sign anything? I assume we could adjust a rate like this so long as it benefits the customer and we document what we're doing and why, but I'm struggling to find a definitive answer in a Reg.