Our account agreement states that the balance to which the finance charge is applied is determined using the daily balance method. Our core system calculates the balance suing the average daily balance method. Which one is correct?
A father and daughter are purchasing 1-4 single-family residence for investment property. What is the appropriate way to complete a Designation of Homestead and Affidavit of Non-Homestead for the daughter that rents her current residence?
What is the status of the CRA revisions?
We receive applications for our home equity lines of credit through our web site. Is it OK to mail the brochure and disclosure after receipt of the completed application?
Regarding the APR on the Closing Disclosure: our ARM rates are set at application. Our Note provides for a 45-day look-back for rate changes. I'm conflicted reading the regulation and want to verify that we should be using the index within that 45-day period before consummation to calculate the APR on the CD? The initial rate is not determined by "index + margin," but changes are based on index/margin/caps. I think they should be using the most current index when the CD is issued. Often times the application date is greater than 45 days from consummation. I believe this is the most conservative approach.