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denotes Guru Question & Answer.
LAR
Collecting GMI on Loans Not Reported on HMDA LAR
HMDA Lobby Notice Posting
HMDA File Review - LAR Requirements
CD Secured Loan & the LAR
Tracking for Census Tracts
GMI Yi-Yi -Yi!
Home Equity Reported on the HMDA LAR?
Reporting FHA/VA Loans on the LAR
Pre-approval Confusion
HMDA Filing Help
What do the acronyms CAR and LAR mean?
HMDA - Reporting the Term of the Loan
HMDA - Transaction Secured by Other Dwelling
CRA Reporting for Community Development Loans

Multiple Properties -- What Gets Recorded on LAR?
Privacy, Compliance, and Disclosures
Is Home Equity 2nd HMDA Reportable?
HMDA with more than two applicants 
Term Used for HMDA Rate Spread Calculation 
We've filed our HMDA LAR - what next?
HMDA LAR "Purchaser" Field Definition
What Determines if a Loan is HMDA-HOEPA
Occupancy on LAR, 2nd Home
HOEPA Test for Denials
What Do We Really Get From Monitoring Data?
Prequals Under HMDA 
Reporting Small Dollar Withdrawn App 
Guru Chatter on HMDA/HOEPA
Lien Status Reporting Under HMDA 
HMDA Help
HMDA: Final HMDA Rules for 2004
Under the Revised HMDA Regs

Funding Institution or Originator: Who is required to record the transaction on the HMDA LAR? 
New loan numbers for customers who reapply
LAR Information Recorded Without Monitoring Info 
Reactivating a loan file as a result of a new application
Civil Money Penalties?
Regulations: Defining Application
Are Business Loans collateralized by dwellings reportable under HMDA on our LAR? 
LAR Mysteries Explained 

Late Payments/Charges/Returns/Fees
Late Payment Charges Paid by Escrow Funds
Untimely Positive Pay Exceptions
Paying Off Late Fees with Escrow Account Funds
Freezing a LOC - Adverse Action Notice
Limitations on Late Charges
Mortgage Late Fee 
COBB Collection Letter
Guidance Needed on Late Charge Assessments
Return Fee and a Late Fee? 
Late Return of Forged Item. Who Takes the Loss?
HELOC Late Fees 
SCRA & Collection Calls on Past Due Credit Cards
Call a Loan Based on a Financial Covenant Violation
What Do We Do With the Overage?
Loan Fees & Late Fees (PDF) 
Fraudulent Items
ACH returned late on closed account
Changing Late Fee on Existing Loans
Using Escrow Account Surplus for Delinquency
Should We ID Bank in Collector's Phone Message? 
Late Charges and Escrow Analysis
Payment Deferrals on a Mortgage Loan 
Collections Calls by Lender 
Late Fee Begets Late Fee
Reg. AA and Pyramiding Late Fees
A Less Painful Collection Method
Military leave
Charging a Fee for Returned Loan Payments
Does Reg O Allow Waiver of a Director's Late Fee?
Balloon Mortgage Terms

Maximum Late Fee for Delinquent Loans 
Reg Z, Late Fees, and Second Mortgages 
Mortgage Notices: Late Charges & Due Date
Who Is Responsible For A Late Return? 
Bankruptcy & Collecting Late Fees 
Can we charge a late fee on a farm loan secured by real estate? 
Endorsed Checks, Stop Payments, Late Return, and Liability 
Late Return Responsibility 
Late Return Claims 
Late Fee Grace Period 
Late Payment Interest 
Calculating Interest On Late Payments 
Late Charges & Past Due Loans 
Slowing Economy: Advice For Lenders 

Legal Opinions
Box Relocations Provoke Lawsuits
UCC & Ambiguously Named Payees
Safe SARs
"Unconscionability" and Other Issues in Mandatory Arbitration Clauses
Email: Two-Edged Sword, Part II - Second Edge
Email: Two-Edged Sword
Prudent Precautions
Question & Answer
"Is It Ok To Deposit Checks Payable To A Corporation Into A Personal Account?"
COUNSELOR'S COMMENT
Federal Court Says "OK" To Pay Large Checks First
Do's and Don't's for DBAs
Who's Got The Power?
Counselor's Corner
Counselor's Corner
Counselor's Corner
Counselor's Corner
Counselor's Corner
Counselor's Corner
Fast Track Program
More On Subpoenas…Non-disclosure
Question & Answer
Cashing Checks For Non-customers
Counseler's Corner
Counselor's Corner
Counselor's Corner

Legislative Moves
HR 946 - Overdraft Fee Bill
HR 323 & CTR Exemptions of Seasoned Customers
New Jersey Bill Would Mandate ATM Panic Buttons
States Looking at ATM Emergency Bills
Difference Between Act and Regulation
Regulations Online
Status of Check Truncation Act 
"That Number Has Been Disconnected…"
FDIC Improvement Act Of 1991
Sympathy Is In Order…
IRA Change Proposed
Keeping Score
Wouldn't That Be Nice?

Lender Liability
Federal Regulations for Commercial Lending
Two Bad Loans Don't Equal One Good Loan
What Would the Jury Think?
Lender Liability Quiz

Lending
SMB Loan Portfolios
Deposit Account Required for Loan Approval?
Provide Another GFE?
Selling Consumer Loans - Notices Required 
Independent Underwriter Appraisal Review
RESPA - Loan on the Land, Not the Mobile Home
HMDA - What Census Tract Info Do We Use?
CREs and TDRs
Document Needed for HELOC Extension
The Great Debate: Credit or Public Records Data
Mobile Home Equity Loan?
BSA Retention Policy & Loan Documents
Deposit to Loan Ratio
Mortgage Credit- Requiring Deposit Acct Prohibited
HMDA Reportable - Tax Saver
Home Equity Loan - Final TIL
Insider Lending - Language in the Note
Loans to One Borrower Limitations
Interest-free Balloon Mortgage - Conforming Loan
Second Mortgage Balloon Rider
ROR Applicable on a Fed Reserve Holiday?
Effect of Interest Rate Calculation Change
Paying Off Late Fees with Escrow Account Funds
Lending DDA Funds
Using CML LOC as Overdraft Protection
Crediting the Aggregate Adjustment
Servicing Sold, Note Retained - Report Loans?
Annual Escrow Analysis Notice
The Auto Dealer, the Lender & the Credit Report
Change in Environment Changes Security Strategy
Simultaneous Closings - Early TIL on 2nd Lien?
Credit Card Reapplication Denied - Adverse Action?
The Flood Insurance Reform and Modernization Act of 2007
In Search of a Real Estate Loan Spreadsheet
HMDA Data - Phone, Internet or Mail Applicants
Who Signs the ROR?
Funding on Warehouse Lines of Credit
IRS Reporting - Payments to Lawyers & Law Firms
Residential Lot Purchase - Maximum Regulatory LTV
P and I Payments - HMDA Reporting
HMDA File Review - LAR Requirements
Commercial Loan Record Retention
ARM Disclosures - Treasury Index Figure
Interest Reporting on Seller's Payments
Refinance or Purchase for Disclosure Purposes?
HMDA Rate Spread - HOEPA Disclosures
Pay Off Quote - Customer Notice
Documents Signed by Non-borrowing Owner
Limitations on Late Charges
Business Loan Collections
Construction Loan Converted to Perm Financing
Non-owner Occupied HELOC - ROR Period
RESPA Bridge Loan?
SCRA Notice - Mortgage Only or All Borrowers?
Hidden Trigger Term?
Flood Zone Re-mapping Notices
Commercial Loan?
Reg B Appraisal Requirement - Construction Loans
Home Equity Application
Purchase of Rental Property - ROR Applicable?
Appraisal Fee Reimbursement
Paid in Full?
Obtaining a Credit Report - Signed App Required?
ROR - Is an Addendum Enough?
Condo Flood Insurance Disclosures
Applicable Disclosures for an Apartment Purchase
HELOC Outside Banner
Fixed Equity Loans - HMDA Reporting Required?
HOEPA & Business Purpose Loans
Reg Z - Definition of Consumer
Equity Line of Credit - Exempt from ROR?
Loan Renewal - Flood Certification Notice
HMDA Reporting on Bahamian Condo
Rental Property Purchase - Final TIL
COBB Collection Letter
Addendum Conundrum
Boat Loan Documentation
Charge-off Amount on the Past Due Notices 
POA Powers
Reg Z & Non-resident Aliens
Construction Loan Increase - New Note Needed?
HMDA Reporting - Refinance of Rental Properties
Waiving a Loan Administrative Fee
Dry Dock Slip as Collateral
Timeframe for Pulling Flood Determinations
ROR Given on the 4th Business Day?
Auto as Additional Collerateral on a HELOC
Remote Capture - Legal Lending Limits
RESPA and/or HMDA Applicable?
GMI - Finance Purchase Price of Primary Residence

Minimizing Risk 
Landlord's Waiver 
Construction Loan & ROR 
Flood Insurance Shortfall 
Which Lending Laws Apply on Inter-State Loans
RESPA Escrow Rules
Texas Property Closing
Loan Denied to Illegal Alien -- Follow-up Question 
Flood Insurance on a Single Unit of a Rackaminium
What are Goods and Services in Lending?
Real Estate Lending Standards - Part 365
Collateral Release
Private Non-federal Student Loan Program
Applications - 3 Day Disclosure Period
Reg O - Keep Names Private?
Schumer Box
Property Value Determined by Tax Value
OREO Property - Special TIL
Is this Renewal HMDA Reportable?
Credit Checks- Bad for the Borrower?
Future Advance Clause
HMDA - Motel Loan
Is This Loan Subject to the Regs?
Annual PMI Notice
Security Interest in Railroad Cars
Lender Signature Required on URLA?
RESPA - Temporary & Permanent Financing
Renewal Notes
Balloon Note Secured by a Deed of Trust
Loan Considerations
Informal Partnership Lending
Income for Home Loan Qualification
Charging a Credit Report Fee at Closing
SAR = Something Ain't Right 
Rating Lenders on Performance - Pros and Cons 
HMDA Definitions of Ethnicity
Two Flood Certifications/Determinations Needed?
Title Updates
RESPA - Bed & Breakfast Loan
Send Stock to be Re-registered
Form 1098 - Mortgage Interest on Rental Propery
Credit Denial Record Retention
Benefiting from Voluntary CRA Data Filing
Disclosing the Annual Estimated Real Estate Taxes
Statutory Bad Debt
Obtain & Retain Borrower's Signature on SFHD
Waiving the Right of Rescission
Cosigners and Guarantors
Reg O - Board Approved Revolving Line of Credit
Closed-end Indirect Lending Auto Loans
Timing of Force Place Flood Insurance Notification
Separate Negative Credit Reporting Notices

One Party Pledging Multiple Party CD
Homestead Rights
"3 Day Docs" Signature Time Frame
Mobile Home Lending and the UCC
RESPA Exemption for Interim Financing?
Wrong Credit Report 
Shady Auto Loan Customer
Gas Certificates - Reporting
2nd Home Purchase 50 Miles from Primary Residence
Reopening a Closed Credit Card Account
Reg B - Intent to Apply for Joint Credit
Trigger Date for Phone Application Disclosures
Charging Interest During the Rescission Period
Defining Temporary Financing, Then & Now 
Loan Officer's Legal Lending Limit
Loan Officer Signing Phone/Mail Applications
Loan Customer an Existing Customer for CIP?
HMDA and the Reverse Mortgage Loan
Digital Storage Fee a Finance Charge Fee?
Escrows & the Aggregate Adjustment
Add an Overdrawn Account Balance to a Loan?
Disclosing Relationships with Bank's Providers
Reg O - Credit Card Extensions of $15,000 or Less
Internet Lending Compliance Issues
Commercial Purpose Loan Made to an Individual
FIRREA Business Loan Exemption
Katrina's Devastation Leads to Loan Denial
Conflict Over Meaning of Abundance of Caution
Unsigned Commercial Loan Application 
Does SCRA Apply to Employees of the Military? 
When is Proof of Flood Insurance Required? 
Refinance of Manufactured Housing 
ROR - Bona Fide Personal Financial Emergency 
Refinance of Manufactured Housing 
HELOC - Notice of Right to Rescind 
ROR - Bona Fide Personal Financial Emergency 
Over-disclosing on the TIL
Bridge Loan Secured by an MMA-HMDA Reportable?
Taking a Security Interest in a Radio Station
Loan officer/Realtor - Disclosure of Dual Roles
Please Define DSCR Requirement
In Search of a Decision Tree Module
Commercial Real Estate Loans Reg B Reportable?
Separate Flood Insurance on Individual's Condo
VIN Number in the Fed Box
Assumption Language on Construction Loan Disclosure
Flood Determination on Lease of Airplane Hangers
LLC Loan - Lending Limits for Guarantor
Collecting GMI When Borrower is a Trust
Examples of Collection Letters
Solicitation Letter, APR, and Disclosures
How Often De We Request W-9 Form?
Determining Reduced Payment Amount under SCRA
Federal Regulations for Commercial Lending
How Soon Must Flood Determination Be Pulled?

The Right to Cure 
Lending to a Numismatist 
Rescission on property titled in LTD Partnership 
Compliance Requirements for Lenders to Consider?
e-Learning on the Front Lines of the War on Terrorism
Negative "Amount Paid to Others on Your Behalf"
Annual Financial Statement on Consumer Loan

Adverse Action Notice Without Reasons 
Is New Application Required for RE Modification?
FI's liability on Indirect Loans & FCRA/FACTA 
SCRA and Sub-6% Mortgage Loan 
Determining Reduced Payment Amount under SCRA

Legality of Consumer Balloon Notes
Launching a Risk-based Pricing Program 
Financial Statement on Another Bank's Forms 
Commercial/Residential Loan -- Consumer? 
Mortgage Applicants Causing Non-Compliance? 
Lending referrals
Re-disclosure By Wholesale Mortgage Lender
FBI Reports Mortgage Fraud Running Rampant
Predatory Lending: The Study and a Verdict
Updating Loan Policy to Reflect FACTA Changes
CRA Compliance Straight Jacket
Mortgage Technologies Elevate Processes and Profits
Construction Loans
Commercial Lending Advisor
Reg Z - Definition of Agricultural Land
Lending Extravaganza Week
Subject to Lending Test & Reporting Requirements? 
Three Days Starting From When? 
Is the Competition Breaking the Law? 
Is this application withdrawn, incomplete, or ???
Indirect Lending Statements 
Consumer loan billing
Differences and Definitions of Loans 
8 Months of "Special" CRA Reporting? 
Notary Witnessing Mortgage with Two Signatures
Does Risk Based Price Need to be Validated? 
Formula for APR on Mortgage Loans 
Are Renewals Enforceable Without a New Note? 
Credit Dispute Checklist 
Origination Fee vs. Points 
Can We Exempt this Loan from Regulation Z? 
Referral Fee for Commercial Loans 
Is a Monthly Statement Required on Open End? 
Lending referrals
Recent CRA changes
Realtor Referrals
Rescindable Purchase Money Agreement
Lending & Mortgage Departments Share Credit Report
Loan Classification Triggers
Disagreement on maturity dates 
Reg U coverage triggers
Who Are Americans?
Flood again, with a different wrinkle
Is This Servicemember Protected by SCRA? 
Lending Reports to the Board of Directors 
Copies of IDs in the Mortgage File, Yea, Nay? 
Making Affordable Housing a Reality
Cutbacks: Helping Small Businesses
Real Estate Lending Cheat Sheets
Dual mortgage origination structure--compensation 
A Little Bit of Optimism Shows Through
Requesting Copy of Commitment Letter
Certificate of Non-Cancellation
Affording a Home in High-Cost Areas
What actions should my institution take in order to expand our Assessment Area(s)?
Lending against Holding Company Stock 
Lending More for Debt Servicing 
Font Size Specifics
Not For Sissies
Limits Built In
Overdrafts Moved to Clerical Position 
Using Wireless For Employees
If a Condo Association Decides Not to Rebuild ....
Indirect Lending Pricing Question
Monitoring Your Correspondent Lenders
Signature to Affirm No Rescission
SCRA Rate Change After Discharge 
Business Loans and Disclosures 
Efficiently Documenting Collateral
It's Time to Kick Off 2005 Business Lending
New federal law addresses bank, military service member relations
Efficient Residential Lending
Guru Chatter on Lending Disclosures (PDF)
What Reg 0 amount to report?
Using CDs as Collateral
Construction Loan Term Limits
Annual Financial Statements
Usurious Loan with CD Collateral
Putting Bank's Charter Number on Flood Form
Motel Loan HMDA Reportable?
High Cost Mortgages: The Unsimplification of Truth in Lending
Monitoring Commercial Lines Of Credit 
E-Disclosures for Real Estate Loans
CRA Data Collection for New Businesses 
Officer Guidance Lines & CRA 
Documenting Receipt of Copy of Appraisal 
Do Not Confuse Income and Revenue

Lien Release Timeline 
Making Loans to Illegal Aliens 
Credit Scoring and Fair Lending

About Business Credit Cards

Altering Collection Notes 
What is the Definition of a Manufactured Home? 
Are there Worksheets for HOEPA Requirements?

Difference in Points and Origination Fees 
Combining Income of Unmarried Co-Applicants

HMDA Info on Brokered Loans 
Rescission When Owner Is Not Borrower 
Exception to LTV Ratio 
EHL Logo Sought 
What CRA is Really About
Incomplete mortgage applications
CRA: Looking At CRA The Hard Way
Payoff-Related Fees 
Disclosures of Fees on Commercial Loans 
Signatures on ARM Disclosures 
Variable Rate Credit Cards 
Disclosures on Pre-quals and Preapprovals 
Documentation: Necessary For Everything
Complying with HOEPA
HMDA: How Did HMDA Happen?
Mortgage Survey for Customers 
Finding Other Lenders' Marketing Materials 
Counteroffers and Denials on Dealer Apps 
Renewing Principal and Interest 
Appraisal Fees on Construction Loans 
Lot in Flood Zone; Building Not 
Application Fee vs. Third Party Fee 
Finding a Real Estate Matrix 
Figuring Income When Some Is Tax Exempt 
SSCRA & Rate Caps
Perfecting a Lien on Aircraft 
HMDA Triggered by Pump Repair Loan? 
Lender's Reimbursement for Rent 
Co-applicant vs. Co-signer
"Financed By" Signs 
Right of Offset 
Reaffirmation in Chapter 7 
Pledging a Jointly Owned CD as Collateral 
"Customization" of HELOCs 
Sub-Prime Lending: Agencies Propose to Collect Sub-Prime Loan Information
Loan disclosures & state law
Cross-collateralization clauses 
Limits on Loan Payment Extensions 
Servicing Disclosure on Denied Applications 
Lending: Preparing "Fringe" Borrowers to Qualify
CIP and Indirect Lending

Balloon Mortgage Terms

Getting Started with Open End Credit 
SSCRA Rate Adjustment

RESPA and a Construction Loan 
Signing One Form for All Disclosures 
Is SSN on Mortgage Illegal? 
Guarantor's Right to a Copy of Note 
HMDA Data Collection for 2003
Solving the Mystery of Credit Scoring Models
Settlement Fees - Attorney vs. Settlement Company
Overriding lending policy
HOEPA Disclosures & Closed-end Home Equity Loans 
Reg Z: Consumer vs. Commercial Loan 
Doc Prep Charges on the HUD-1 
SSCRA Applicable to Enlistees? 
Rescission: Disbursing Funds Without Signature 
Written Notice for Changing Equity Line Terms 
Disclosures: Single Acknowledgement Form or Individually Signed Disclosures? 
Early TIL for "To Be Determined" Purchase 
TIL Disclosure: Required Deposit & Demand Feature
Reg C, HOEPA, and Maturity

TIL Disclosures for Loans to Trust
Taking Delinquent Loan Payments From A CD
Adding A Question To Equity Line Credit Application
ARM (LIBOR) Interest-only Loan Calculation 
What is the definition of "unimpaired capital"? 
Multiple Problems With Old Mobile Home Loans 
Special Financing for Flood Victims 
Home Equity Loans, Property Purchases, and HMDA
Dealer Loan Portfolios & Fair Lending Concerns 
CIP & Mortgage Lenders

Is a mobile home loan rescindable?
Are your Internal Controls like Swiss Cheese? Part 8
Using UTMA Account As Loan Collateral 
1098 Reporting & Motor Home Loan 
Construction Loans & ROR

Offering Loan Products In Spanish 
Placing Floor Rate On Existing HELOCs 
Home Equity Loan, Rental Property Collateral, and HMDA 
Required Home Equity Disclosures 
New Unique Lending Solution That Increases Productivity, Reduces Costs, While Enhancing Customer Satisfaction 
Reg Z & Construction Loans To Family Members 
Student Lending Incentives
Small Business Owners & Credit Evaluation
Escrow Analysis Audit

Improving Home Equity Loan Processing and Closing
Bridge Loans & ROR

Consumer Construction Loan Disclosures 
What are the maximum interest rates on CD loans?
Loan To A 16-Year-Old

Using Maiden Name On Loan Documents 
Can We Convert Balloons To ARMs Prior To Maturity?
Real Estate Employee Referral Incentive Programs
Predatory Lending under Regulatory Scrutiny
Extending Credit To Employee Secured By ESOP
Modifying Secured Loans 
Condo loans & flood insurance
Flood Certifications & Balloon Loans 
Does the renewal of a crop loan require a new UCC?
Real Estate Loan To Illegal Immigrant 
Community Bank Student Loan Program
Lending to Businesses with Cash Flow Problems
Reactivating a loan file as a result of a new application
Credit Score Disclosure and Internet Applications 
When is a Web Application an Application? 
Faxed Mortgage Loan Application 
Retention of Denial Documentation
AA on Loan Application - 2 SARs Filed on Customer 
Reg. B and Small Business Lending
Real Estate Application Requirements
Loan Denial Notice
Form 1003 and Joint Intent 
Joint Applications -- Special Procedures?
Application fees, credit reports, and disclosure
HMDA -- Recording a Withdrawn Application 
Font Size Specifics
When Are Early Disclosures Required?
HMDA, Home Purchase Loans and the "Date of Action"
Timing of Insurance Disclosures 
Are Internet Applications Like Mail Applications 
Collecting Government Monitoring Information
Loan Denials for Third Party Applications 
Credit Bureau Reports Without Written Permission 
Disclosures at Application 
"Joint Credit" Acknowledgments on FS Updates 
Permissible Purpose to Access Credit Reports 
Determining Joint App Intent Over the Phone
Reg. B -- Withdrawn Application
Joint Credit Notice on Mortgage Applications
Documenting the Loan
GMI Reporting Issues for Branch Applications 
Birthdates for Loan Applicants
Removing an Applicant, New Application? 
Birthdates for Loan Applicants
Removing an Applicant, New Application? 
ECOA Notice Requirement

Industry Standard for Documenting Joint Apps

Wording for Consumer Loan Apps
Complaint Resolution Under RESPA 
Incomplete mortgage applications
Application Defined for Early Disclosures 
Withdrawn mortgage applications & disclosures
Lien Status Reporting Under HMDA 
Prescreening on an Individual Basis 
Loan Applications & OFAC
Denials, withdrawals, or incomplete applications
Issues with Applications in PDF Format 
HMDA Reporting of Originated and Purchased Loans
CIP and Birthdate Info on Loan Apps 
Loan Apps and CIP Changes

Is new information required on every application? 
Online Loan Applications, Disclosures, and CIP 
Changes in Monitoring Information Collection
Telephone Mortgage Applications & Required Early Disclosures 
New loan numbers for customers who reapply
Using Maiden Name On Loan Documents 
Retention of Loan Customer Driver's License Info 
Real Estate Loan To Illegal Immigrant 
"At the time of application…" 
Using Real Estate To Secure A Car Loan 

Lending Limit
Remote Capture - Legal Lending Limits
Reg O - Readily Marketable Collateral
Reg O - Single Insider Aggregate Lending Limit 
Over the Legal Lending Limit?
LLC Loan - Lending Limits for Guarantor
Limits on Lending to Affiliates 
OCC addresses real estate lending calculations, limits
Legal Lending Limit 
Letter of Credit
Letter of Credit Refusal Notice Defects Lead to Liability
Voest-Alpine Trading USA Corporation v. Bank of China
Letter of Credit Refusal Notice Defects Lead to Liability
Levy
IRS Tax Levy - Funds Less than Amount Levied
Levy on Account Receiving SS Deposits 
Levy the IOLTA Too? 
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