AThe bank only marks “Yes” for the rate lock if there is a written rate lock agreement. See the preamble to the final rule 78 FR 80225
“. . . Accordingly, where a creditor has a policy to honor the quoted
rate, but does not lock the rate pursuant to a written agreement with the
consumer, the creditor would disclose “no” pursuant to §1026.37(a)( 13)
(i). . .” (Response provided August 2018.) ■
ABOUT THE AUTHORS
LESLIE CALLAWAY, CRCM,
CAMS, CAFP, Director of
Compliance Outreach and
Development, along with
managers MARK KRUHM,
CRCM, CAFP, and RHONDA CASTANEDA, CRCM, serve as a compliance
resource for ABA member banks. Among other managerial duties, the team is
responsible for manning ABA’s Compliance Hotline, serving on compliance
committees, and providing content and guidance for ABA courses.
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Answers do not provide, nor are they substitutes for, professional legal advice.
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