Most Popular Operations Content
Performing Risk Assessments
11/03/2008
What individual risk assessments is a bank expected to perform? How do the individual risk assessments fit together with an "enterprise risk assessment"?
Loan APR Discount
11/03/2008
When advertising an APR discount on a loan product, do you have to specify which loans qualify for the discount? For example: Save .50% APR on Green auto loan rate. Do you need a footnote to define "Green"? Thanks
OCC WIN Calculator - Odd Days Interest
10/27/2008
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?
Update Original Reports & Use the Same Appraiser?
10/27/2008
A customer/owner wants to have his apartment property appraised using two methods- "as is" and "as if unimproved" (land value). After the appraisal is completed the customer wants to obtain a bank loan to finance either a rehab or new construction. Under FIRREA, can the bank engage the same appraiser and have the original reports updated?
Broker Required to Send Servicing Disclosure?
10/27/2008
Are brokers required to send a servicing disclosure to borrowers if they are not acting as the lender, such as a broker that will fund the loan with a line of credit and then sell it to the investor?