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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Lenders and Document Imaging Software

02/21/2021

How can a document imaging system make lenders more efficient?

Debt-to-income ratio

02/21/2021

Does the General QM still require a 43% debt-to-income ratio.

Action Taken Date

02/21/2021

On files that are closed for incomplete, we have been using the date the form expires as our action date for several years now, but your manual states, the date of the form. Do we need to be looking to change that, or since we have been doing it this way for several years, do you think we will be OK as long as we stay consistent?

Military Status and Foreclosure

02/14/2021

If our borrower hasn’t requested SCRA protection and is past due on her mortgage, can we start foreclosure as we normally would?

Hazard Insurance Policy and NFIP

02/14/2021

Is it true that the NFIP will only pay out if the borrower has hazard insurance in place on the property? Our bank's practice is to get hazard insurance at closing, but doesn't monitor for it after that. If the hazard insurance policy has expired and there is a flood, will the NFIP pay out?

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