Most Popular Lending Content
Fair Lending, CRA, and Targeted Marketing
09/15/2003
If we were to target say a hospital and offer aspecial program to all employees (such as free checking, a special CD rate, a special mortgage interest rate, etc., toqualified applicants) would there be any repercussions as faras fair lending or any other compliance issues?
SSCRA Applicable to Enlistees?
09/15/2003
With respect to the Soldiers and Sailors Civil Relief Act (SSCRA), I understand debts incurred prior to entry into the military are subject to the 6% interest rate cap. Does it matter whether or not the military member voluntarily enlisted in the military? I thought the SSCRA would apply only if someone was drafted into the military.
Disclosures: Single Acknowledgement Form or Individually Signed Disclosures?
09/15/2003
For the upfront lending disclosures (e.g., Servicing Transfer Disclosure, ARM disclosures, etc.) for which the Bank is required to keep a customer-signed acknowledgement of receipt, can the Bank substitute a "Disclosure Acknowledgement" form which the customer signs acknowledging receipt of all the disclosures? Or do the regulations require that the disclosures be individually signed?
Home Improvements, New Improvements, and HMDA Reporting
09/15/2003
Client is requesting a $13,000 home improvement loan paying off an unsecured $3,000 home improvement loan with additional funds of $10,000 for new improvements. This is not reportable in 2004 as a refinance. Should it be reported as a home improvement loan or not reported under HMDA at all.
TIL Disclosures for Loans to Trust
09/15/2003
Is the grantor of a trust required to be given the Truth in Lending disclosures when a loan is made to a trust?