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.
We are preparing a 3 month deferral of payments ONLY not extending maturity. The property is in a special flood zone. Is it a requirement to pull a new flood determination?
We are new to auto loan lending and had a general question about allowing credit cards for monthly payments (including our own credit cards). Is this a wise business practice? What is the industry standard for making auto payments via credit cards?
We are looking at charging fees for credit reports. We have never done this. How do we do this correctly? We are looking for any recommendations or guidance you can offer.
Consumer 1st lien mortgage originally set up as a 30 year with a 5
year call. Loan matured February 1st, bank did not renew until April. Since
this was renewed after the original maturity, big discussion started. Some
think it had to be a new loan, others think a renewal would have been fine.
You date the renewal docs the maturity date but have April as the signing
date? Would that have been okay? Instead they did a whole new loan and the
consumer had to pay for all the closing costs again. A new Title Policy and
I am doing a HELOC for under $250,000 as a 1st Deed. Is a full interior appraisal required or can a desk-top valuation be done?
May a home improvement loan be treated as a single transaction construction-to-perm loan?
If so, is the draw period/construction period exempt from RESPA servicing rules or do they apply because it is not initial construction of the property?
Here is the scenario: the borrower already owns a house and is taking it down to the studs and will have all new finishes at the completion of construction. He is also paying off two existing loans. Following the construction phase, the borrower will obtain permanent financing through our bank.
At what point can a late fee be assessed on consumer loans?
Who are the key stakeholders when it comes to deploying a loan imaging system?
New HMDA requirements include reporting an introductory rate period. The regulation tells us to report the number of months until the first potential rate change with fixed rates being reported a "NA". Does that mean on a daily variable loan (generally rental properties) we report a "1" since the rate could change in less than one month?