Most Popular Lending Content
APR matrix For Fees
07/15/2002
Is there a matrix out there (Mary Beth probably has one!) that charts APR issues like if a fee falls into what category: fee, finance charge, and prepaid finance charge, or exempt/excluded? I tried to sit down with Reg Z and make one for our bankneedless to say, I am now emailing you.
RA9, Continuation, And The Need For An Initial Filing Statement
07/15/2002
I noted on your Roadmap that you indicated a transaction subject to RA9, with security interested perfected under old A9, perfected by filing, in the correct state, with the correct filing, should be continued prior to the normal lapse date by an initial financing statement. I was under the impression that a correctly filed security interest subject to a UCC1 filing under old A9 that meets all the requirements of RA9 should be continued by virtue of a UCC-3 continuation within the window period prior to the normal lapse date, not by an initial filing statement. Please clarify the need for an initial filing statement. Up to this point, I had understood that the initial filing statement was the means to maintain your lien position at the same time you were "correcting" or bringing into compliance with RA9 a filing not meeting the requirements of RA9, but for which you had been perfected under prior A9.
When the Borrower's Home is Owned by a Business
07/08/2002
by Mary Beth Guard, BOL Guru
CAC: The Consumer Outlook
07/01/2002
The Consumer Advisory Council ("CAC") met for the second time this year and discussed the hottest topics of interest to consumers: privacy notices and CRA.
Privacy
The 45 Day "Rule"
07/01/2002
Our bank feels that the first payment date on monthly installment loans cannot be more than 45 days from the date of the note. I've called the FDIC and they know of no requirement like this. A prior bank had a rule that if the installment loan was 12 months or more, the first payment had to be between 19 and 51 days out. If it was under 12 payments, there was a narrower window for the first payment. Does anyone have a clue if these are old wives tales or is there some legal basis to this?