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Separating the Appraisal and Evaluation Functions - Mary Beth Guard
09/27/2004
Separating the Appraisal and Evaluation Functions
Answer by Mary Beth Guard, BOL Guru
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SCRA Rate on Student Loans
09/20/2004
I realize that, under the old SSCRA, Section 1078 of title 20 was interpreted to trump the interest rate cap on student loans. The newly enacted SCRA does not make any reference to this. Does this section still trump the interest rate cap?
HOEPA's Treasury Rate Calculation
09/20/2004
The FFIEC Guide to HMDA Reporting provides two clear examples of how to calculate the Treasury yield based on whether the interest rate was set prior to the 15th of the month or after the 15th of the month. On interest rates set prior to the 15th of the month you would use the Treasury yield for the prior month and on interest rates set after the 15th of the month you would use the Treasury yield from the same month as the lock. I would like to confirm that the Treasury yield used for HOEPA purposes (I realize the Treasury yield is triggered by the application for credit date and not the lock date) is calculated in the same manner. There seems to be some differing opinion in that no matter what date the application was taken, the Treasury Yield would be used from the previous month. Please clarify this for me.
Rescission, New Loan, New Lender
09/20/2004
Is right of rescission applicable on a transfer of lien from another lender on a customers primary residence?
BSA Training Requirements
09/20/2004
What is considered adequate training under the Bank Secrecy Act for bank employees? Might this vary based on their duties?