I need some help with the right of rescission rule interpretation. On a refi loan, if the borrowers receive all TRID disclosures on a Saturday but our offices are closed that day so their signatures would have to be made on Monday. My question is, when should the 3 day rescission period begin? On Monday- Wednesday ( based on disclosures received on Saturday) or Tuesday-Thursday ( based on the effective signing date of Monday)? Reg Z states: 1026. 15(a)(3) i. The period within which the consumer may exercise the right to rescind runs for 3 business days from the last of 3 events: A. The occurrence that gives rise to the right of rescission. B. Delivery of all material disclosures that are relevant to the plan. C. Delivery to the consumer of the required rescission notice.
We have an online loan application that our members complete. It does not have a signature on it. We use that to pull credit, make the loan and the members come in and sign loan documents. My question is do I need them to complete a loan application in person with a signature or is the on-line application sufficient?
Are all transactions that are HMDA reportable counted toward the thresholds?
We have a customer who asks for random people's help by having them issue checks to him and he provides them cash (more than the amount on check) in return. For us, it's suspicious but don't know what is the best reason to put in the SAR?
How are lines of credit that do not revolve treated; are they open-end or closed-end?