[newbee05]

Clarification on the CD/Savings Account secured loan. If we are dealing with a covered borrower, the law prohibits the bank from extended a loan secured by a deposit account; however, the MLA does not prohibit the bank from taking a security interest in a deposit account during the term of the loan (I.e. in the event of default). Am I interpreting that correctly?

If not, will you please clarify? In either event, will you please provide a citation that I can reference?

[newbee05]

Is it possible for a loan originated prior to 1/10/14 to have not been considered high-cost at the time of origination, but subsequent to the 1/10/14 effective date to then become a High Cost Mortgage making it then subject to the servicing provisions in 1026.34?

[newbee05]

On the ACH question, if a payment is scheduled to be made on a date that falls on a non-business day, it is my understanding that we process the ACH on the following business day, but the payment is made effective the date of the transfer.

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