16 HќќѠіђџȱ юћјђџ юѦȱ2014 COMPLIANCE CONNECTION Question: Consumer Loan Fees – What are the new consumer loan fees and other adjusted amounts for consumer loans that are allowed in Indiana? Answer: The Uniform Consumer Credit Code (UCCC)1 is the part of the Indiana Code which outlines the types and amounts of fees which ęȱȱ¢ȱȱ and other trigger amounts related to extending credit to consumers. Some of the fees and trigger amounts ȱěȱ ¢ȱŗȱȱȬ numbered years. The key revised fees and trigger amounts which ȱěȱ ¢ȱŗǰȱŘŖŗŚǰȱȱ listed in the chart at right; however, due to a drafting inconsistency in House Enrolled Act 1245 from the 2014 legislative session, some of the referenced amounts will adjust beyond these changes provided by the Administrative Code, as described in the following footnotes. ȱęȱȱȱ take the necessary steps to ensure that all IT systems are updated to Ěȱȱ ȱǰȱȱȱȱ will include the new fees in all loan documents beginning July 1, 2014. Additionally all loan origination, ǰȱȱȱěȱȱ utilizing this information should be made aware of the change. All current fees listed above, and other fees related to the UCCC, can be found in the Indiana Administrative Code.6 ABOUT COMPLIANCE CONNECTION In order to address compliance inquiries from members, IBA provides Compliance Connection, an assistance ȱěȱȱȱ Ȭęȱȱ ǯȱ ȱȱĴȱȱȱǰȱ ȱ Compliance Connection will refer the bank to a law ęǯȱ ȱȱȱȱȱ ȱȱ¢ȱLarry C. Tomlin, partner with Krieg DeVault LLP, Indianapolis, and IBA compliance consultant. Submit Compliance Connection questions to IBA’s Amber R. Van Til at avantilȓǯǯ This information is provided for general education purposes and is not intended to be legal advice. ȱȱȱȱȱęȱȱȱ to how this information applies to your institution’s circumstances or situation. 1 IC 24-4.5 et seq. 2 House Enrolled Act 1245 from the 2014 legislative session will further amend this amount to be $4,000 as of July 1, 2014. 3 House Enrolled Act 1245 from the 2014 legislative session will further amend this amount to be $4,000 as of July 1, 2014. 4 House Enrolled Act 1245 from the 2014 legislative session will further amend this amount to be $4,000 as of July 1, 2014. IC Section(IC 24-4.5…) Dollar Amounts Provisions Relating to IC 24-4.5-2-201(7) $ 2,000/4,000 Graduated rate (sales) IC 24-4.5-2-201(8) 48 Minimum credit service charge IC 24-4.5-2-203.5(5) 18.50 Delinquency charge (sales) 2-407(4) 1,110/3,7002 Security interest (sales or leases) 3-201(7) 48 Minimum loan finance charge 3-203.5(5) 18.50 Delinquency charge (loans) 3-508(6) 2,000/4,000 Graduated rate (supervised loans) 3-508 (7) 48 Minimum loan finance charge 3-510(2) 3,7003 Land as security (loans) 3-511(2) 1,110/3,7004 Maximum loan term 4-301(4) 1,110 Property insurance 5-103(7) 3,7005 Deficiency judgment 7-104(2) 605 Principal loan amount 7-201(4) 605 Graduated rate scale 7-404(3) 605 Combined loan amounts 5 House Enrolled Act 1245 from the 2014 legislative session will further amend this amount to be $4,000 as of July 1, 2014. 6 750 IAC 1-1-1 Carrier selection is one of the most critical decisions in a BOLI purchase. Not all BOLI providers offer carriers with the top AAA rating. Executive Benefits Network offers its clients the most highly rated BOLI carriers in the industry; delivering the long-term benefits and financial strength our clients expect. Now that is Knowledge You Can Bank On.™ We Peel Back the Layers So Our Clients Can Fully Uncover BOLI. ©2014 EBN BOLI & Deferred Compensation Experts 800.780.4EBN ebn-design.com
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