What does FFIEC stand for?
Our institution has a mortgage loan secured by the borrower's business; the loan proceeds are for personal use. The borrower wants this set up as a single-pay but our loan originating system keeps bringing up a negative amortization warning and ask the originator to switch to a balloon payment or ARM. Is a single-pay an option or is it not allowed for a consumer purpose loan?
We would like to start charging for credit report fees at our financial institution. Are there any fair lending considerations that we should be aware of (especially where pulling joint credit bureau reports is concerned)?
We would like to start charging for credit report fees at our financial institution. Are there any fair lending considerations that we should be aware of (especially when pulling joint credit bureaus is concerned)?
We currently have Home Equity Lines of Credit (open ended) that have floor rates of 6.00% and 7.00% and we would like to reduce these to our new floor rate of 4.25%. I know under Reg Z Section 226.5b (f) it states we can make a change that will unequivocally benefit the consumer throughout the remainder of the plan. With that being said what type of documentation and disclosures must be given in order to stay in compliance with the regulators and terms of the loan? We want to ensure that if we do a modification agreement on the HELOC we do not need to redisclose on the loan.
What rate is used to calculate the interest rate on a loan that is secured by a Certificate of Deposit account? The interest rate on the Certificate of Deposit or the APY on the Certificate of Deposit?
I unsuccessfully searched for "528.2a". Can you tell me the status of this nondiscrimination regulation? I was interested in the part that says lenders should have available a copy of their lending standards available upon (a consumer's) request.
What method(s) are being used to determine insurable value when calculating the appropriate amount of forced placed insurance?
A National Bank customer defaults on an installment loan due to delinquency and the loan is charged off on December 31, 2002. The customer continues to make payments and brings the loan current in 2005. The customer asks the bank to rebook the charged off loan, the bank agrees and a new loan agreement is signed in March 2006. In December 2006, the OCC regulators tell the bank to charge off the new loan (their reason: a bank can not rebook a charged off loan) even though the loan was current and paid as agreed. Since the customer was not at fault and the bank was in error to rebook the loan, how does the bank report the loan to the credit bureau? Do they use the original date of December 2002 or December 2006?
To disclose or not to disclose: a new loan to a trust secured by a second lien on a CEO's (trustee of the trust) primary residence to pay off his business' "asset based line of credit", due to inadequate A/Rs has been approved. The loan officer says that the purpose is still commercial. Do you think the regulators will look at it more as a commercial loan or a consumer loan? Should I prepare the rescission notices to go out with the deed?