MarchMarch 9 is the due date for comments on the Federal Reserve Board's proposal to amend Regulation C, HMDA, to increase the information reported on the LAR.
We are currently offering a 5/1 ARM at 5.50% with caps of 2/6. Margin of 2.75 based on 1 yr t-bill. Currently the T-bill is 2.06 therefore using this as an estimate for future payment changes results in the rate lowering with the 61 st payment. This then results in a lower finance charge throughout the life of the loan and therefore calculates an APR that is lower than the rate. Is this correct? I'm not seeing other banks with similar products disclosing a similar APR.Any information you have would be greatly appreciated.
We have an application for a loan to purchase a residence which is secured by another dwelling owned by the applicant. What do we record in the property location section of the HMDA LAR?
Concerning Reg Z and the TIL form, when we find that our bank has improperly disclosed the APR and Finance charge on a mortgage loan, how do we go about calculating the reimbursement? Does this always automatically trigger a reimbursement? I have tried to find info on it in the regulation but have not found anything to help.
We have a loan request from a company contemplating that one of our outside directors would guarantee the loan. What would be the treatment of the loan under Federal Reserve Regulation O?