Vendor Guru Q&A - Lending

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Latest Lending - Overdraft Charges Topics

Max Fee for NSF Check Returned for CC Payment

09/22/2019

What is the maximum fee allowed for a NSF check which was returned for a credit card payment? And is there a maximum fee for late charges for credit cards?

Electronic Right of Offset

08/20/2007

Our lending operations department (not credit card) would like to initiate an EFT through our third party vendor to debit our customer's deposit account to exercise our right to offset for amounts owed on our customer's loan. Our deposit account terms and conditions discloses our right to offset any amounts owed to the bank. We know that generally Reg E, Section 205.3 (c)(5) would allow the bank to electronically transfer funds between a customer's accounts without the customer's specific request under certain circumstances and that the official commentary provides that this exception to Reg E includes the right to initiate "electronic debits or credits to consumer accounts for check charges, stop-payment charges, NSF charges, overdraft charges, provisional credits, error adjustments and similar items that are initiated automatically on the occurrence of certain events." In order to exercise our right to offset electronically, the transaction will need to be processed through our third party vendor. Do we have any Reg E or other regulatory concerns in doing so?

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Limited English Proficiency

10/13/2019

Do we have to provide translators for loan applicants who do not speak English?

Flood Insurance for 2 Properties

10/13/2019

We have a loan with two properties. One is a flood zone and one not in. The value of the property in a flood zone is $50,000. Can we require flood insurance only on the amount of the property that is in the flood zone or do we have to get flood insurance to cover the entire $250,000.00 loan balance?

Initial Disclosures Before Underwriting?

10/13/2019

Are initial disclosures required to have the borrower(s) signatures prior to going to underwriting for initial review? I understand that the loan estimate and 1003 need signatures but what about the other initial disclosure documents i.e.: toolkit, counseling forms, servicing disclosure, AfBA, FACTA, Privacy, Patriot etc..

Docs to Verify Income or Tax Returns Required?

10/13/2019

We have a married couple wanting to fill out a home loan application. They state that they do not have any copies of their tax returns. Can we use the other documents to verify income or are the tax returns required?

Correction Method for ACH Refund Error

10/13/2019

A loan customer gave us permission to originate ACH transactions to pay his loan payments. I originated a payment on the 30th of the month and a payment was posted to his loan. He then paid the loan in full. In error, I originated an ACH to refund the loan payment. Then I received a return of the payment on the 30th from his bank for a closed account. But they did not return my refund origination for account closed. The bank confirmed to me on the phone that the account is closed so I asked why they didn't return the refund for account closed, I was told they could not discuss the transaction. What is the proper 'correction' method and wouldn't the bank have some sort of responsibility to return ALL transactions on a closed account?

Latest Lending - Overdraft Charges Topics

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