For banks that provide combined ECOA-FCRA disclosures, is it standard practice to “Check the 1st Box” and provide FCRA credit score information if the decline reason is not based on the consumer report, but some other factor? (i.e. insufficient collateral, product not offered, out of lending area) Do other banks do this? We understand that we do NOT have to “Check the 1st box” and provide credit score information if it was NOT used in making the adverse decision, but what would be the risk to provide this information in the above cases?
Are we required to disclose on a consumer payment deferral agreement that deferring a payment will lead to paying additional interest over the life of the loan and a larger final payment?
What has been the most recent change to flood insurance compliance?
We include the Equal Housing Lender logo in all our home loan ads. Are we also required to include the “Equal Opportunity Lender” logo?
Reg Z covers individual consumer use for credit cards plus a few sections which are for business use, one of which is for unauthorized use if the business has been issued 10 or more cards. What is the rule and/or regulatory expectation on how to handle legitimate billing error claims (i.e., charged the wrong amount) from business card accounts? And, are there common business practices used in this scenario such as something parallel to the individual consumer rule in TILA, 1026.13?