When advertising loans does the loan amount used to calculate the APR matter? Can that amount be different depending on product? Can the lending department arbitrarily select a loan amount of $250,000 to calculate the APR on conforming loans and use $750,000 for jumbo loans?
For loans which have odd days, the OCC WIN calculator gives a message that APR is over or understated if we do not enter the odd days in the calculator. When we do enter the odd days the APR disclosed by us is within tolerance. Does this mean that for these loans we will need to collect odd days interest at closing? At present we do not collect or disclose odd days interest. For instance, a loan made on January 16th with a first payment date of February 29th, the amount financed is $1,500, the APR is disclosed as 7.5969% and the finance charge as $105. The payments are $88.68 per month for 18 months. Now if odd days are set to "0" in OCC WIN, the calculator states a violation that APR is understated by 0.3064%. If we enter odd days as 13 in the OCC WIN, we get the disclosed APR to be within tolerance. Does this mean that we need to disclose odd days and collect it at closing?
I am an assistant manager at an in-store branch. The bank compliance officer tells me I can't advertise our mortgage or auto rates without disclosing the APR. It was my understanding that this must be disclosed when actually PROCESSING a specific loan. I thought I had seen newspaper ads w/o the disclosed APR. He told me they were probably mortgage companies. Is he correct? Must we disclose the APR even in advertisements? If so, are there restrictions on HOW it is disclosed, such as spreading the fees over the life of the loan vs. using the first year only (which makes the APR higher)? Are there any fees that we can leave out of the APR?
We are getting ready to launch a promotional mortgage rate product if the borrower opens and maintains a DDA with a specific threshold balance. Is there specific language to disclose this promotional product to the borrower and then secondly, what special considerations would need to be given if a mailing or other form of marketing is conducted?
The Federal Reserve Board staff has held constant and issued a proposed update to Regulation Z's Official Staff Commentary in time for the holiday mail.
When you have a loan administrative fee or a loan fee how do you disclose the APR? The fee is not included in with the amount financed, but is included in with the finance charge and it does raise the APR. For example a loan of $4,000.00 at a rate of 6.90%, $20.00 loan administrative fee, has an APR of 7.1596%. A loan at $5,000.00 at a rate of 6.90%, $20.00 loan fee, has an APR of 7.1061%. If you are running a loan special what APR do you use if they are different?
HUD has published a proposal to make significant changes to the Good Faith Estimate that lenders issue within three days of taking an application. HUD calls this a "simplification" of the GFE.
Truth in Lending, and its close ally, Regulation Z, have been at the center of the compliance circle from the beginning.