Do you have to disclose owner's title insurance on the Good Faith Estimate for a construction-permanent loan?
I've been asked to research what compliance issues there might be with changing our CD early withdrawal penalties from interest based (e.g., 3 months interest) to principal based (e.g., penaltiy is 1% of principal amount at opening or renewal).In what I've been able to find, the only thing I see relates to the Reg D requirements for the penalty to be at least 7 days simple interest if the withdrawal occurs within the first six days to be considered a time deposit. Assuming we can cross that hurdle, are there other compliance issues that I'm missing? UDAAP potential comes to mind, but if we are clear and transparent in disclosing the penalty are there other aspects of UDAAP that could bite us? We are looking at this as a defensive/customer retention tactic. With today's rates so low, and as a result with interest-based early w/d penalties also low, customers have no real downside to locking in higher yields today by putting into long term CDs with the thought that if rates jump significantly in a year, the penalty will be more than offset by moving to a higher yield CD early.I'd be interested in hearing any thoughts. We have heard anecdotally that other banks may be considering or already doing this. Is anyone aware of a bank doing this at this time?
We have a borrower who is refinancing his home, which was previously in a flood zone. The prior Flood Determination is less than seven years old, so I know we can use the previous Determination. Must we send a new Flood Notice to be signed?
Is there a way to find what the Visa Procedures are that must be followed when doing a debit card dispute?
When we have a non-profit organization our bank titles it like "Jane Doe D/B/A as Girl Scouts Troop 55" and uses Jane's Social Security number. Where I worked at before titled accounts in the form "Girl Scout Troop 55" and used their own tax number. Can accounts be styled two different ways?