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April 24
BSA/AML Compliance: Writing the SAR Narrative
Ken Golliher

April 29
HSA Basics
Whitney Johnson

April 29
Required Training for Loan Originators
Mary Beth Guard and Jack Holzknecht

May 13
Overdraft Practices in Today's Regulatory Environment
John Burnett

May 14
Reg E Claims - Allocating Liability Correctly
Andy Zavoina

May 15
Managing Electronic Information - From A to Zettabyte
Fred Menge



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#1669124 - 02/23/12 02:54 PM Approved ARM to 30 yrs fixed
YVeitia Offline
Junior Member

Registered: 08/17/11
Posts: 29
Borrower submits application for ARM loan which gets approved but not accepted. Borrower requests 30 years fixed instead, file goes back to underwriting, new disclosures are furnished and borrower accepts. Would you report the approved and not accepted ARM and also report the approved and accepted 30 years fixed? My gut feeling tells me to report only the approved and accepted 30 years fixed. Thanks for your input.
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CRCM,CAMS

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HMDA
#1669145 - 02/23/12 03:12 PM Re: Approved ARM to 30 yrs fixed [Re: YVeitia]
RR Joker Offline
10K Club

Registered: 11/15/02
Posts: 15770
Loc: The Swamp
I would think you would report both.
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My opinion only.

Say You'll Haunt Me-Stone Sour

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#1669150 - 02/23/12 03:29 PM Re: Approved ARM to 30 yrs fixed [Re: YVeitia]
David Dickinson Offline
10K Club

Registered: 11/28/00
Posts: 13799
Loc: Central City, NE
Sounds like 2 separate applications to me - both should be reported. Doesn't sound like a negotiation.
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David Dickinson
http://www.bankerscompliance.com

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#1669158 - 02/23/12 03:23 PM Re: Approved ARM to 30 yrs fixed [Re: David Dickinson]
YVeitia Offline
Junior Member

Registered: 08/17/11
Posts: 29
Thanks guys,
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CRCM,CAMS

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#1669359 - 02/24/12 08:55 AM Re: Approved ARM to 30 yrs fixed [Re: YVeitia]
Dan Persfull Offline
10K Club

Registered: 08/28/02
Posts: 40014
Loc: Bloomington, IN
I am going to offer a differing opinion based on how I'm reading the original post.

Applicant applies for an ARM loan. It is approved but the applicant changed their mind and requested the terms be changed to a fixed rate product. The requested changes are approved and the loan is consummated.

We would treat this as an amended application and only report the origination.
_________________________
The opinions expressed are mine and they are not to be taken as legal advice.

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