25 Mar Compliance for Loan Payment Deferrals
During these unprecedented times, banks may be asked by customers about loan payment deferrals. While this can be a straightforward process for consumer non-real estate loans and business loans, residential real estate loans can be a bit more challenging. You will need to address Truth in Lending Act (Regulation Z), Real Estate Settlement Procedures Act (escrow), Unfair, Deceptive, or Abusive Acts, or Practices, Fair Lending (Regulation B), flood, and credit insurance requirements in these situations. Contact KPM Manager Richard Dugas for guidance on how these issues may affect your financial institution.