If we have a rate sheet that we give to real estate agents and our loan originators, but we know the true use will be for them to hand it to consumers or post it where consumers can readily access it, wouldn't we need to have the APR on it?
RESPA - is it a thing of value if a Realtor puts on their open house flyer a preferred lender's info?
How can the “compliance aid” provision be used?
Why are first lien home equity rates being measured against a residential Average Prime Offer Rate (APOR) when these are two different products? It is hard to explain to a borrower that their home equity rate is priced higher than the average rate of an entirely different product, thus resulting in an escrow requirement.
On our old operating system we provided a TISA disclosure to our business customers when they opened a certificate of deposit (CD). Our new operating system separates personal accounts from non-personal accounts and does not automatically produce this disclosure for a business customer. Only a CD receipt is generated for non-personal. It lacks interest calculation and detailed penalty information. The two products function identically. By providing our business customer with the TISA disclosure we are ensuring that they receive detailed interest calculation and penalty information. We think it's important for them to receive this information to avoid UDAAP concerns. Rather than reinventing the wheel, it seems simpler to give them a TISA disclosure. Do you see a problem with providing a TISA to our CD business customers?