11/03/2024
Is it okay for us to share subscription services that the bank has access to with our mortgage service providers?
11/03/2024
To get an auto loan our credit union requires the person to be a member. This requires a deposit/share draft account. Is this an allowable requirement to qualify for a loan?
11/03/2024
Are we required to use a rate sheet for commercial loans?
10/27/2024
We are transitioning to a new loan software program and have noticed the Negative Information Disclosure document provided at closing is not providing a signature line for the borrower to sign. Our current loan software has the signature line that isn't removable so we have always assumed it was required. I cannot find any information in the regulation that a signature is required. 1) Is a signature required and 2) If it is not required to obtain signature, is it required that we retain a copy of it with the closing package to show examiners it was provided at closing? It just seems odd from what we have always seen and would like to know if we should request a signature line be added.
10/27/2024
Overdrafts may be one issue, but what about a late fee waiver on a loan for bank director - would this be a violation of Reg. O?
10/27/2024
We have a credit card product that has an introductory “fixed” rate that changes after 12 months to a variable rate APR. Management wants to really promote that fixed rate period, but I don’t think we can use the word “fixed”, can we?
10/27/2024
Is it a TRID violation if the File # is missing or incorrect in the closing information section of the closing disclosure?
10/20/2024
If a financial institutions normal process for commercial property loans is to start appraisal bids/engagements post-decision, can there be fair lending violations for starting appraisal bids/engagements pre-decision for customers based on length of relationship with the financial institution, credit exposure with the financial institution, etc?
10/20/2024
As part of an initiative to be able to sell to secondary market we need to set up reporting to all credit bureaus. Currently we only report to Equifax.
I am wondering if there are any compliance concerns if we only report to all bureaus for some loans (mortgage loans) and not others (in house branch originated) or mortgages vs. other loan types, commercial vs consumer, etc?
10/20/2024
We have a number of residential loans that sit on several acres of property that i would consider 1B if it were vacant, i.e., "usable for agricultural purposes." Should these be classified as 1C2A or 1B on the Call Report? The definitions leave room for interpretation. For example, a loan for a single family residence that sits on 100 acres.