We have a HELOC originated in 2008 that moved into the repayment phase in May 2018. The initial rate was WSJ prime and remains at WSJ prime (no margin) throughout the repayment phase. The loan has a interest floor of 3.75 percent so the rate has been set at that since May 2018. Since there is no set change date to enter in our system the CFPB ARM notice will not generate to give advance notice if the rate increases. Are we required to provide the ARM notice, and if so are these circumstances that allow the notice to go after the fact?
Is the term adjustable rate mortgage (ARM) reserved for a consumer loan product or can a bank offer an ARM loan as a commercial loan product secured by CRE?
We have a Fire Department Association account that is causing tremendous headaches. I need some advice. The fire chief and assistant chief who set up the account have recently resigned from the volunteer department and the city has appointed new members. As the new accounts representative for the bank, I received a letter from the city, signed by city council members requesting the removal of the previous chief and assistant and for the new ones to be added. My problem is that the previous assistant chief is now claiming that the city had no authority over the funds and should never have had the original names removed from the account. My stand is that the monies belong to the association and since he or she resigned from the fire department, he or she has no more claim to the funds than an average citizen. Can you shed some light on this for us? We are also seeking advice from our legal counsel since this is such an ongoing issue in this small town that it will most likely result in legal action.
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.
Fair Isaac Corporation and IBM recently announced a partnership to offer new services to banks designed to help them fight fraud enterprise-wide instead of relying on the more traditional method of
We have a customer refusing to endorse her checks. She stated that it is our (Depository Bank) responsibility to stamp the back of the check "credited to the within named payee". I have not heard of this, nor can I find any information on customers refusing to endorse their checks for deposit.
I am confused by the TILA 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 fixed rate, then for the remaining 20 years of this 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.
We have exterior electronic message boards at most of our branch locations and would like to display our 5 year ARM rates. Are there special rules/exemptions for electronic advertising? What must we disclose if we include the rate?
If a Realtor were to describe a property, a single family residence, and also state "Special Financing 5% Down, No PMI, $1612.06/Mo." would the requirement to disclose an APR be triggered? If so, what would be the violation for not doing so? Incidentally, this is an advertisement on a $429,900 listing.
The agencies are in the process of publishing new examination procedures for the new components of anti-money laundering programs generated by the USA PATRIOT Act.