Vendor Guru Q&A - Lending

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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New HPML Rules Defined

12/04/2022

Under the new QM/ATR rules that take effect on Oct 1, 2022, when does a loan become HPML? Is it still based on the 1.5%-1st lien, 3.5%-2nd lien, or does it now go by the new thresholds in the price-based tiers, for instance, 1st lien is less than $68,908 has a 6.5% threshold between the APR & APOR?