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?
If we have a rate sheet that we give to real estate agents and our loan originators, but we know the true use will be for them to hand it to consumers or post it where consumers can readily access it, wouldn't we need to have the APR on it?
I have a client (a lender) who orders their credit reports from "XYZ Data" and when a loan is declined, they list Equifax on their Adverse Action Notice (with appropriate address and phone number) and they have now been told that because "XYZ Data" is considered a reseller of credit under the FCRA 603(u) that they should also list XYZ Data (along with its name and telephone number) on the Adverse Action Notice. Is this true?
Can a lender purposely not get one of the six TRID items to avoid getting an application in order to delay the loan estimate delivery date?
Does the monthly life insurance policy fee need to be disclosed on the loan estimate and closing disclosure on 1st and 2nd mortgages? The policy is offered by the lender but it is not a requirement of the loan. This one is on a 2nd closed-end mortgage and the monthly fee is included with the P & I payment for the mortgage.