RESPA Sec. 3500.7(C) requires "...the estimate of the charges and terms for all settlement services must be available for at least 10 business days from when the GFE is provided,..." Should we count Saturday as a business day?
We have a direct mail letter going out that has a coupon for $150 off closing costs for a new mortgage and no closing costs for a home equity. We do not advertise any rates, as this will be an ongoing mailing. What do we need to disclose?
Our consumer lenders and marketing departments have figured out a way to increase car loan volume. For newer cars and requests greater than $5,000 they'll offer gas coupons. For customers who don't qualify for the government's Clunkers Program, this may be an incentive to choose us for borrowing. What issues do we need to watch?
Is anyone out there doing Marketing Servicing Agreements with builders? We've had some builders approach us and want us to pay them $500/month for the privilege of putting our logo on their ads and my RE department says other banks are doing this. I think it would be a RESPA violation if you cannot prove the $500 is the actual cost of the bank's portion of the ad. If anyone is participating in this, I'd like to know how they got around the RESPA requirements.
We have a CPA in our community who handles 80% of the areas business payroll. Could we do joint advertising with him on a flyer that promotes our debit card if he shares the cost of the marketing materials? Are there any compliance issues?
Our commercial lenders want to place an ad that mentions a prominent bank customer in the residential construction industry in an ad. This customer is being mentioned in return for marketing efforts in increasing their volume of business with the bank. Are there any regulatory issues of concern?
A local pizza firm has proposed that the bank print complimentary pizza coupons to give away to customers at no cost to the bank (other than printing) and to also furnish flyers to place on the top of the pizza boxes. The retail value of the pizza deal is $15, but the bank would not be responsible for this cost. The owner of the pizza firm would absorb the pizza costs. This does not give me a warm and fuzzy feeling, but I cannot locate any regulation that would suggest that this would not be a good idea. I don't think RESPA would apply since there would not be any R/E advertising or referrals.
We are having a "new account sale" where we offer a gas card for opening a new account. What are the stipulations on paying the employees of the gas stations a flat referral fee for the day of the sale?
We are looking into setting up a referral and rewards program for our HELOC Visas. We would like to both give our members a $50 gift card upon closing of a HELOC, as well as pay out $50 gift cards for referrals that end up booking. I hear different stories about limitations being either $25 or $600. Are there limitations? What would the dollar amount be?
One of our mortgage loan officers wants to do a mailing to potential loan customers offering a $100 gift card to use at local retailers. What issues come into play with this?