Bankers Threads
Click to return to BOL home page
Banker Store Read A Reg BOL Insiders Career Connect Learning Connect Bankers Information Network

Learn more about

MEMBERS


















Have a Question?
Looking for a
Product or
Service?

Our Vendor
Advisory Board









IMPORTANT!
BankersOnline SURVEY
Today only - a quick 33 questions
We need your input. We are deploying a survey today that asks 33 questions about how your institution is dealing with the impact of the lending compliance regulations that took effect in January, 2014. We're taking a snapshot in time. The survey, which is anonymous, will only be available for 24 hours. We are asking for the participation of every financial institution that uses BankersOnline. [One survey per institution, please.] Help us capture an accurate picture of where we are with lending compliance right now. We estimate you should be able to complete the survey in about 10 minutes depending on how familiar you are with your bank's products and history. Most questions are multiple choice with the last two asking for a short narrative. We appreciate your feedback.
Click NOW to complete the survey.

Topic Options
#1869264 - 11/07/13 10:15 AM Small Creditor Exemption
CNBAudit Offline
New Poster

Registered: 11/07/13
Posts: 4
We have a master loan purchase agreement with several correspondents. We take the application which is underwritten by the correspondents underwriters. We receive a written commitment to purchase at the loan approval and we distribute our funds at closing. We immediately transfer the loan to the correspondent after closing and receive final funding within a few days. Must we count these loans in our 500 or fewer small creditor calculation.

Top
Ability to Repay/Qualified Mortgage Rule Forum
#1869266 - 11/07/13 10:14 AM Re: Small Creditor Exemption [Re: CNBAudit]
rlcarey Offline
10K Club

Registered: 07/16/01
Posts: 50412
Loc: Galveston, TX
The loans are in your name as the creditor - correct?
_________________________
The opinions expressed are my own, take them or leave them.

Top
#1869271 - 11/07/13 10:19 AM Re: Small Creditor Exemption [Re: CNBAudit]
CNBAudit Offline
New Poster

Registered: 11/07/13
Posts: 4
Yes - the loans are originated and funded in our name and then immediately sold

Top
#1869286 - 11/07/13 10:32 AM Re: Small Creditor Exemption [Re: CNBAudit]
rlcarey Offline
10K Club

Registered: 07/16/01
Posts: 50412
Loc: Galveston, TX
Then they are your loans whether you held them for 10 seconds or two months.
_________________________
The opinions expressed are my own, take them or leave them.

Top