Non-real estate loan applicants can use our online form to request a loan. Based on their address we will know if they are in or out of our market area. In some cases an online request is stopped before a credit report is pulled and the person is not allowed to complete the application because they receive a message saying they are outside our market area. The bank does not send any other other notification. Are we required to send an adverse action notice if the bank's practice is to not make these type loans outside of our service area?
What types of documents do bankers store in loan files?
This question is regarding incomplete mortgage applications with an address. (ie: Refi's) Here is the scenerio: Bank approves an application based on the information provided by the consumer, mails the approval letter out which states that based on the application and credit report their loan has been approved subject to the verification of income, assets, and any additional documents deemed necessary from underwriting.
The lender then sits on the file for several months without contacting the customer and then withdraws it stating it is being withdrawn due to no contact.
Should this considered an incomplete application based on the consumer not getting the required documentation to the lender or can it be considered withdrawn since there was no contact with lender since the approval letter?
I cannot find the record of retention for ATM/Debit Card applications or alterations in the state of MI. How long must they be kept?
I once read something that stated the Equal Housing Lender logo (EHL) should be displayed anywhere a home loan application is received. Should a national bank have the EHL logo displayed on each loan officer/customer service desk where home loan applications are received or is the lobby poster sufficient?
The bank wants to give a gift under $25 for all customers who fill out applications for credit cards or loans. This promotion will be held at branches in certain areas, but not statewide. Flyers will be available at all the personal bankers' desks. What would be the compliance requirement?
Marketing wants to advertise that we have instant approvals for online applications. In fact, we will look at the credit score and terms requested, but some applications will be told their request is pending or is referred to a lender for review. I'm not keen on this ad from a compliance perspective, but what can I say to back this up?
Can a foreign national obtain a credit card?
Is there a certain sequence for state tax ID numbers? Do they start with a certain number per state/county?
We have scripted disclosures for telephone applications on credit cards that include the Schumer Box disclosures. Marketing is trying to get us to reduce the talk time on the call. Reg Z says the disclosure requirements do not apply if the call is initiated by the consumer. Do they really mean that we can allow someone to apply by telephone without being given the Schumer disclosures? Do you have any guidance or thoughts on the matter?