TOPIC: Loans

Underwriting Guidelines for Unsecured Loans

VP at a bank ($648MUSA)
We are tightening down our unsecured lending guidelines. I am curious what others are doing? Are you only allowing existing customers to obtain unsecured credit? How are you determining the amount of unsecured credit that will be extended (% of net worth or % Gross Income)? Are all unsecured credits made as installment loans or are you allowing single pays? Do you have different term limits depending on installment vs. term? Any feedback related to underwriting an unsecured loan would be appreciated.

    Credit Balance on Non Consumer Loans

    Person at a bank ($667MUSA)
    Does anyone know if there is anything in the regulation that states what the dollar limit is, which allows the bank to not refund a customer of $5.00 or less on non-consumer loans?
    I've been searching Govregs.com and I don't find anything specific to non-consumer.

      NEW YORK STATE - INTEREST RATE DISCLOSURE

      Manager at a bank ($4.2BUSA)
      In NY we are required to provide an Interest Rate Disclosure to the mortgage loan applicant to make them aware of when their interest rate for their loan will be set.  We are going to a new loan vendor and they use DocMagic to generate the loan documents.  

      We lock our rate at application.  The DocMagic form does not have that option.  The DocMagic vendor is recommending that we use a Lock-In-Agreement instead, using the date of the application as the Lock In Date.  My concern is that we are not advising the applicant when the rate will be locked (prior to locking).  Maybe it is just semantics.  Does anyone else in NY, lock the rate at agreement and have Doc Magic as their loan document vendor?  Do you use the Lock In Agreement?

      I look forward to hearing your thoughts.       

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          Truth-In-Lending Disclosure

          SVP at a bank ($2.2BUSA)
          We have decided to start offering consumer loans starting with loans secured by CDs.  While we will eventually get a loan documentation system, we do not anticipate a heavy volume of loans to start so we are using a template consumer note and related documents.  The one document I have not been able to find is a template of a Truth-In-Lending Disclosure.  I can create via Word or Excel but before doing so, I figured I would ask the CBANC Community.  Anyone have a template they can share?  TIA.

            Moving from LIBOR to SOFR: Smoothing the Transition for Your Financial Institution

            LIBOR has been used for over three decades as the global standard benchmark. This will soon be changing and financial institutions will need to adjust their loans to the new benchmark, the Secured Overnight Financing Rate (SOFR). To help you prepare, check out our white paper for a background and comparison of each rate, solutions to the challenges ahead and more. Read White Paper: http://go.pcbb.com/2019-SOFR-and-LIBOR-WP-Request.html

              Reg O Questions - Related Interests, Reporting, Etc.

              AVP at a bank ($3.4BUSA)

              Not getting responses in another group I asked, so hoping this might reach more people! Thanks so much.

              1. Do you report related interest loans on your Call Report, and if so, do you only report the amount of % owned by the insider or do you report the full loan balance?
                1a. Which figure should be used for in-house Reg O reports?

              2. Do you track/report loans that are excluded, such as overdraft lines? Interested in the pros/cons of doing this.

              3. Are loans to related interests of an Executive Officer excluded from the $100,000 limit, and only subject to the 215.4 limitations, as long as the Executive Officer does not personally guarantee the loan?

              4. If an insider’s loan is grandfathered in due to timing of insider election, do you still obtain a demand clause or do you just notate the dates and reason for exclusion?