Breaking Archive

Q: When can borrowers with Paycheck Protection Program (PPP) loans submit their loan forgiveness applications? A: As set out in Interim Final Rule #20, borrowers can submit a loan forgiveness application any time on or before the maturity date of the loan—including before the ...Read More

Q: Can the bank convert a HELOC that is getting close to its maturity date into a closed-end, amortizing loan without requiring TRID disclosures? A: Unfortunately, no–if during the loan term a HELOC is converted from open-end credit to closed-end credit, that would trigger ...Read More

Q: If our customer is on a COVID-19-related forbearance plan (and she was current before the bank agreed to the plan), do we use special comment code AW (affected by natural or declared disaster) and code CP (account in forbearance) and will either affect ...Read More

Q: It is my understanding that the aggregate amount of extensions of credit to executive officers cannot exceed $100,000 for Regulation O purposes. If an executive officer has a loan that is guaranteed by FSA or SBA, is the guaranteed portion of that loan ...Read More

Q: If we doubt the collectability of a check that a customer presents to the Bank, are we able to put “an indefinite” hold on the funds? A: While Reg. CC does not specify the allowable duration of an exception hold for this reason, the Reg. ...Read More

by Dhruv Sharma, McGlinchey On Jan. 1, California’s Consumer Privacy Act (“CCPA”) went into effect, activating the most onerous privacy regime in the nation. Broadly speaking, CCPA grants consumers the right to know what personal information is being collected from them; know how that ...Read More

Question: This is a HMDA question. Borrower was scheduled for closing, but because a home inspection that the borrower ordered did not go as they planned, the borrower ended up cancelling closing. The bank did not require this inspection and all underwriting conditions had ...Read More