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?
Our customers who want e-disclosures click on an “Enroll Me” link. Is that good enough for compliance?
If we send e-statements are we required to monitor whether they are being read, and if the customer is not opening them, do we have to revert back to paper?
How much do file cabinets cost for storing loan files?
We like having customers sign up for Internet banking when they open their accounts. Is this acceptable for E-SIGN, or is more needed?
How does integrating our LOS to an imaging system increase the value of our LOS?
Does UDAAP apply to just consumers, or all customers?
Have the agencies taken any action against influencers?
What are current CFPB Regulatory Initiatives?
What is Native Advertising?