07/10/2006
Are there any regulations that prohibit our bank from sending a monthly loan statement to our client? Our client has a Commercial Real Estate business loan and would prefer he did not receive the monthly statement. He is set up for an automatic transfer from his checking account to pay the loan monthly.
07/10/2006
We are currently sending a "Credit Reporting Warning" along with a past due notice for our customers when the customers account reaches 40 days past due. Our auditor's say the warning should be given with the first 10-day notice. Which is correct? Where do I find this information in the Regulations?
07/10/2006
Disclosure for Reg DD NSF Paid/Returned and Overdraft Fees starts on July 1, 2006. Can Year to Date fees start to track as of that date, or must they track from the beginning of the year?
07/10/2006
I am confused by the Truth in Lending rules and FTC Guidance (How to Advertise Consumer Credit) on how to advertise the following product: 10/1 LIBOR ARM. Repayments are "interest only" for 10 years with a fixed rate, then for the remaining 20 years (30-year loan), the rate becomes variable and the loan is amortized for principal and interest payments. At a minimum, our line of business wants to advertise the amount of the monthly payment. Is this a Graduated Payment feature loan, or a Discounted Variable Rate Plan or something else? Any real-life examples are appreciated.
07/03/2006
Our bank is trying to increase deposits and our marketing department is proposing that we offer a special introductory rate on our money market accounts for six months, after which the rates will adjust to our normal rates. The money market account is a tiered rate product but this introductory rate will be offered across the board. I know there are advertising concerns when listing a teaser rate on HELOCs. Are there any special advertising rules I should watch out for?
07/03/2006
If a bank declines a loan application because the applicant has exercised his right to file for bankruptcy would this be considered a violation of Reg B?
07/03/2006
Our settlement agent charges a fee of $10.00 for digital storage. Our loan processing/closing supervisor received a memo from the settlement agent that this fee is/would be charged on comparable cash transactions, would this fee be considered a finance charge fee?
07/03/2006
Our customer has a contract on his or her primary residence to sell within the next 60 days, and the house is free of debt. The customer wants to refinance and use the proceeds to go towards the purchase of his new home. The proceeds from the sale of the old home will go to payoff our loan. I know that RESPA does not apply to Bridge loans, so no Good Faith or Servicing Disclosure is needed. What about a preliminary TIL and Right of Rescission?
07/03/2006
I have a question about the final truth in lending. How much can the amount financed be overstated? I know that there is a $100.00 variance for understating.
07/03/2006
Can collection calls be made on past due credit card accounts that are currently protected under the SCRA act?