On a unsecured note, what address has to be on there. Can it be the mailing address which is a PO Box or does it have to be the borrowers physical address?
We are looking to increase our late fees on our consumer loans (installment and line of credit) not affecting any HELOC or mortgages at the first of the year. I know based on our current disclosures we cannot increase late fees on existing loans but can on the new loans made going forward. I am looking to see if we need to provide our membership with a notice of increase in fees? If so, does it need to be in a newsletter or can it be a hard coded message on the statements? I can't seem to locate this within Reg Z rules.
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?
The primary collateral for a loan is business assets, although a dwelling was also taken as collateral. Is this loan not reported for HMDA?
If an APR fee is paid at closing by the lender should it still count as a APR fee the borrower pays?