Most Popular Lending Content
Do We Disclose if We Charge Back a HELOC Check?
10/25/2004
If a credit card or HELOC account isn't subject to Check 21 but a check drawn on these accounts can become a substitute check, do we have to make a consumer awareness disclosure if one of these checks bounces?
Do We Send Disclosures to HELOC or Credit Card Accounts?
10/25/2004
Many credit card and HELOC accounts allow customers to take advances by writing checks. Will we need to make Check 21 disclosures to these customers?
Will Credit Card or HELOC Checks be Imaged?
10/25/2004
Are the checks that a consumer might draw against a credit card or HELOC account eligible for truncation and reconversion under Check 21?
Loan Denials for Third Party Applications
10/18/2004
Do Notices of Adverse Action need to be sent when application is sent to a bank by a dealer/merchant?
RESPA Referral Fees
10/18/2004
Our Internet branch has proposed a new idea, but I am worried about violating RESPA’s "referral fee" and "splitting fee" regulations. They want to recruit tax preparers (during their off season) to "team up" with our loan officers. The tax preparers would call their tax clients and offer to assist them with their mortgage needs (purchase loans, refinance loans, etc). The tax preparer would then take down personal information (i.e. income, assets, debt, etc) and give the information to their loan officer teammate. The loan officer would then do the rest of the work (i.e. final application, processing, etc). Once the loan funds, it is proposed that the tax preparer would receive 20% of the loan officer’s commission. Is this a violation of RESPA?