Most Popular Lending Content
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)?
Charging a Fee for Returned Loan Payments
01/19/2004
We would like to implement a $25 returned payment charge when a loan payment drawn on another institution is returned to us NSF. This charge would cover our costs of reversing the loan payment and sending the NSF check back to the customer. When customers have a deposit account with us, we don't reverse the loan payment if the check is NSF. Instead, we just overdraw their deposit account and the overdraft charge is handled on the deposit side. As we cannot do that with payments drawn on another institution, we would add the $25 returned payment charge to their loan balance(not to the principal). What are the Reg Z or other federal regulation considerations for this? I do not see this specific situation addressed in Reg Z, and did not see anything on the BOL website addressing this either.