Guru Question & Answer .LAR HMDA LAR - Boat Dock & Lake House Purchase Revocable Living Trust & HMDA LAR Reporting CRA Loans & HMDA Logs HMDA – Repurchase of Loan CRA LAR – Coding Group Homes Reporting Non-Mortgage Loans under HMDA GMI on a HELOC - Home Purchase or Refinance Determining Income 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 Prequals Under HMDA Reporting Small Dollar Withdrawn App Guru Chatter on HMDA/HOEPA Lien Status Reporting Under HMDA HMDA Help HMDA: Final HMDA Rules for 2004 Under the Revised HMDA Regs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 Capturing Never Payment Behavior Employee Loan Policies SCRA Notice in Past Due Mortgage Notices? SCRA – Is 6% the Interest Rate or the APR? Customer Refuses to Pay Escrow Increasing Interest Rates on Past Due Loans Cost of Undisclosed Debts by Borrowers to Lenders Mobile Home Late 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 HERA 2008 Temporary IRA Distribution Suspension Act of 2008 Status of Internet Gambling Bill 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 Business Purpose Loan - RESPA Applicable? Looking for a Cure HMDA - Data Reporting Owner Occupancy HMDA Re-file ARM Loan - No Adjustment Schedule Flood Map Revision Fair Lending Flood Insurance & Mobile Homes Flood Map Revision Purchase Money Home Loan Refi – ROR? HMDA LAR - Boat Dock & Lake House Purchase The Equal Credit Opportunity Act Reg O – Sold Loans Reg B - Completed Applications Loan Guaranteed, Not Cosigned – Compliance Issues? Advertise a Discounted Loan Payment Mortgage Relief Scams Real Estate Lending & Trusts Credit Score Disclosure -Interim Construction Loan Government Monitoring - Absent Joint Applicant Business Loan Denial Notice Premium Disclosure Loan Rate for Army Reservist Second Review for Denied Applications ECOA Applicability - Joint Vs Individual Credit Confirmation the Appraisal Notice was Provided Appraisal Rules Point & Fee Test or APR Test? HMDA – Which Date Do We Use? Condo Flood Coverage All Signers Sign the ROR? ROR on RV? Home Mortgage Refinance - Flood Search Required? Disclosures Within Three Days of Credit Report Bank Debiting Account after Loan Charge Off Quarterly CRA Reporting - Updated Income Levels General Interest Law v UCCC Loan Sold to Investor - Borrower Closing Costs Loan To Cost Guidelines Flood – Loan Secured by Leasehold Mortgage Refinancing for a Better Rate – ROR Applicable? Real Estate Transaction Fees Land Only Loans - Early Disclosures Required? Change in Terms Agreement Definition of Permanent Takeout Commitment Needed TIL Disclosure Statement - List Fees? Reg Z - Lot Loan to a Family Trust New RESPA Rules - Tolerance for Fees RESPA – Compliance Vs Lender Revocable Living Trust & HMDA LAR Reporting Flood – 45 Day Notification/Waiting Period Flood Certification Frustration Flood Determination Request Loan to LLC Sole Owner - HMDA or Purchase Money? Lending & the E-sign Rule Curing a ROR Notice Violation Reg U - Purpose Loan Vs Non-Purpose Loan HMDA – Loan Coded as Business/Residence Combo ROR on Mortgage & HELOC Closing Simultaneously Handling the Interest on a Loan Renewal CRA - Logging Company a Small Farm Loan? CRA Reporting - Small Business/Small Farm Loans ROR on Mortgage & HELOC Closing Simultaneously Handling the Interest on a Loan Renewal RESPA – Short Term Loan Fixing HOEPA Violations Commercial Loans – What’s HDMA Reportable? Reg Z - Inspection Fees in the Finance Charges Do a Flood Determination for Each Property? Combining Loans – Does ROR Apply? HMDA Reporting – Mixed Used Property Loan Adding Spouse to Open-End HELOC Secondary Market Loans Acquired HELOCS - Change in Terms CRA Loans & HMDA Logs Loan Modification – HMDA Reportable? Three Year Balloon Mortgage Owner Occupied Second Homes & Vacation Homes HOEPA & Bridge Loans Reg B – Joint Credit & Cosigners Reg B Intent to Apply Jointly – Phone Application Disclose Fees Borrower Doesn’t Pay? GMI on Refinance Q & A - Clarification Needed NDIP Referral Fees HMDA Reporting - No Written Pre-Approval Program Reg O - Bank Holding Company Chairman Funds Disbursed Prior to ROR Date Renegotiating Indefinite HELOCs Refinance Denied – Send Adverse Action Form? Mobile Home Loan a Residential RE Transaction? Mortgage Ad and Trigger Term Placement POD Account as Collateral on Loan Banner Ad Trigger Term Placement PMI - Send Out Amortization Schedule HUD Fee Disclosures Creditor Challenges with Small-business Fraud Credit Verification Retention Resubmit Disclosures in Surviving Spouse's Name? Not Subject to HMDA Reporting – Collect GMI? New Servicing Disclosure Statement Form Credit Grantors need Effective Fraud Tools Sending Email Ads to Selected Brokers Red Flags Rule Requirements for Small-business Portfolios No Flood Notice Given - Force Place Flood? Definition of a Restructured Loan Imposing a Default Rate of Interest on a HELOC Reg Z - Open End Credit Line Increase Duplex Refinance Differences Between Business Fraud and Consumer Fraud Challenges in Identifying Small-business Fraud Red Flags Rule Requirements for Small-business Portfolios Disclosure Required on LTV Ratios Change? RESPA - No Disclosures Required? Calculating Exposure to Payment Card Industry (PCI) Standards New TILA Pre-Disclosure? HERA 2008 Credit Bureau Reporting – Advance Notices Protect Against Small Business Fraud Overdrafts Covered by HELOC RESPA -Residential Lot Loan Secured by Residence Business ID Theft, Account Takeover, Never-pay Protect Against Small Business Fraud Freezing an Unsecured LOC – Notice Required? Credit Report – Signature Required on Phone Apps? Mobile Home as Collateral – Do a Flood Search? Balloon Loan - RESPA Disclosures HMDA Reporting – Loan Secured by Lien on Dwelling Force Placed Flood – Notification Independent Appraisal – Notice Still Applicable? CRA - Loan to Deposit Ratios ROR on HELOC Renewal? Fair Lending - Income Verification HOEPA - Minimum Loan Amount Reporting Credit Life/Disability Insurance Program Question Types within Knowledge-Based Authentication ROR on HELOC Renewal? Fair Lending - Income Verification Denied Loan Retention Schedule Commercial Loan to a Sole Proprietorship LTV Reporting Rule HELOC Rate - Floating or Fixed? Percentage of Exception Loans Changing LTV Ratios HMDA Reporting - Closed-End Lines of Credit Preliminary TIL No Longer Required? Loan Privacy Policy Documents Loan Denial - Census Tract Number Forty Year Mortgage HOEPA Test Risk Based Pricing Model – No Historical Data Reducing the Incidence of Never Payment Developments in Fraud Trends and Solutions HMDA Reporting - Modified Construction Loan GMI Data on Commercial Loans Higher Priced Mortgage Loan Rules HUD 1-A Form Line 1604 Mitigating the Risk of Never Payment New Auto -Loan - First Payment 90 days Flood Certificate – One Time or Life of Loan? Question the Purpose of the Loan? Unsecured Legal Lending Limit for National Banks Car Dealer Indirect Loans – Application Process Not a HMDA Reporting Bank - URLA Required? Corporate Loan Regulation Never Payment Bank Querying Customer on Age & Retirement Plans SCRA Notice in Past Due Mortgage Notices? RESPA - Non-Borrowing Owner Sign Initial TIL & GFE DIC Insurance Policy In Lieu of NFIP Policy? Provide Copy of Appraisal on Commercial RE Loans? Flood Insurance – Bank Owned Collateral Property Purchase Force Place Flood Insurance on Day 46? Bust Out Losses and Traditional Credit Losses Capturing Bust Out Losses When Does Bust Out Occur and on What Accounts? HMDA Reporting - Swimming Pool Secured by Dwelling Adverse Action- File a Copy of the FCAI Disclosure Flood - Life of Loan Certification Coverage RESPA – Title Company Broker Fee HMDA - Double Reporting? 15 Year Historical Example on a HELOC Disclosure Interest Incorrectly Documented on Consumer Loan The Latest Fraud Trends and Solutions State the Rate or Just the APR? Converting Closed-End to Open-End Credit Co-Borrower Added - Provide New Early Disclosures? Deed of Trust as Collateral – Give ROR? Multiple One Month HE Loan Extensions Business Purpose Statement Form Shares of Bank Stock as Collateral SCRA – Report Delinquent History on Credit Report HMDA – Repurchase of Loan HMDA – Report as a Purchase or Refinance? RESPA - Rental House Refinance Flood Determination Date & ROR Paying Tellers a Referral Fee – RESPA Violation? Vacation Home Subject to HUD’s Reg X? Internet Based Loan Applications Tainted Appraisal? Co-Signer Required to Sign the Notice? SCRA – Is 6% the Interest Rate or the APR? Additional Funds to Complete Home Construction ESIGN or UETA Mandatory Flood Coverage on All Buildings? Business Purpose and Exempt from RESPA? Loan Secured by Son's Home - HMDA Reportable? HMDA Reporting - Selling a Participation Loan Borrower Discontinues Loan Application Business Purpose Statement Disclosing PMI Provider Collateral Mortgage on Parent’s Residence - ROR? Definitions Needed 90 Days for Non-Accruing Interest Rule Flood Insurance Rules & Commercial Condos Revolving LOC Secured by CRE with a Low LTV Obtain New Flood Determination at Extension? Hold Car Title as Collateral Against Charge Off Delay Disclosures Until Completed Application? Reg O Reporting - Standby Letter of Credit GLBA and Customer Information Lending Office Issuing Cashier's Checks Reporting Rules for Open-End & Closed-End LOCs SCRA – When Does Active Duty Begin? Flood Insurance - Additional Premium Owed Construction Loans & Section 32 Guidelines ARM Disclosure - Table Not Required? CRA LAR – Coding Group Homes Banks and the Servicemembers Civil Relief Act (SCRA) Collateral & Purpose Codes Travel Trailer as Added Collateral on Lot Loan Classifying Farm Land for LTV Purposes Equal Housing Lender Sign - Latest Version Combining a Consumer & a Commercial Loan Please Define RCBAP The Identity Theft Prevention Program's Impact on Customers Loan Officer is a Realtor - A RESPA Issue? Reg B & Business Loans The Temporary Liquidity Guarantee Program (TLGP) Shutting Down a Revolving LOC – Compliance Issues Reg O – Participation in Major Policy Making No Customer Response - Send Another Action Notice? HMDA Reporting on Entities Timing of Early TILA Disclosure Balancing Risk and Reward Reg R Section 218.701 Compliance Adverse Action Notice - Calendar or Business Days? FDIC Ruling Applicable to Commercial Loans? Entitled to SCRA Relief? Non-Borrowing Spouse Signing TIL & RTC Forms Mobile Home on Property – Loan on Land Only HELOC - No ROR Required? Mobile Home on Property – Loan on Land Only HELOC - No ROR Required? Loan APR Discount Purchased Note - Treat as Refinance? About the Housing and Economic Recovery Act Adverse Action - Ex is Only Source of Income Is the Assumption a Refi or Purchase Purpose Loan? Assumable Mobile Loan - Which HUD Form Do We Use? OCC WIN Calculator - Odd Days Interest Update Original Reports & Use the Same Appraiser? Broker Required to Send Servicing Disclosure? Commercial Loan ARMs? HOEPA - Combined Transaction Loan HELOC Secured by a Second Home Is This HELOC Renewal Considered a Refinance? Property Deemed to be in the SFHA Disclosing Vendors Used in a Mortgage Loan Appraisers & the GFE App Withdrawn/Denied - Collecting an Appraisal Fee Reduce Interest on a Loan - Modification Needed? Reflect All Fees on HUD Prepared by a Title Co? My Home Is & Isn't in a Flood Zone About ID Theft Provisions HELOC Suspension Letters - 202.9 Requirements Adverse Action - Separate the Reasons for Denial? Phone Apps & Collecting Government Monitoring Data Reg B, HMDA & Pre-Approval Letters Flood Zone Change & the Grandfathering Rule Loan with an ROR - Date Interest Accrual Starts Son Taking Over Deed & Debt Retention of Declined Online Credit Applications Customer Refuses to Pay Escrow HMDA Reporting - Use Original Lock-in Date? Must We Redisclose Thousands of HELOCs? Only Current Customers Eligible for Credit? Dedicated Regulation O Officer Are We Required to Get Marital Status on Loan App? ROR on Loan to Move a Home Holding Check in Escrow During Rescission Houseboat Purchase - HMDA Reportable? ROR on Refinance of Non-Owner Occupied Home Holding Check in Escrow During Rescission Reg B - Separate Apps for Joint Borrowers? Balloon Loan Modification Disclosures Reporting HMDA Data to the Board HELOC Modification Or a New Loan Required? Seller Paying Fees Due at Closing Advancing Funds on a Matured Line of Credit Website Screen Record Retention Disclsosures for a Complete App with a Property Notice to Home Loan Applicant Required? Maximum Number of Reasons for Declining a Loan RESPA on Rental Homes Change in Terms, No New Money, ROR Needed? Disclosures to Father Who is Loan Co-Signer Tolerance for an Understated APR Violation Reporting Non-Mortgage Loans under HMDA HMDA - Swimming Pool Loan Secured by Automobile Minor Auto Loan - Parent is Co-borrower Providing Loan Disclosures - Maximum Time Allowed Increasing Interest Rates on Past Due Loans Houseboat Loan - Residential or Consumer Loan? Credit Bureau Reporting Required? 401Ks & Qualified Retirement Plans as Collateral Offering A and H Insurance on a Real Estate Loan 401Ks & Qualified Retirement Plans as Collateral Second Homes Subject to ROR? Mortgage Modification - No Need for Redisclosures? Supervisory LTV Limits ARM Product Disclosures Manual Underwrite Recommendations Bridge Loan Extension- Early Disclosures Required? We Don't Do HMDA Reporting - Do We Collect Info? Commercial Loan Referral - Paying a Finder's Fee Flood Zone - Must Determination & Policy Match? Spouse Not on the Loan - Collecting Spousal Info FDIC Loan Definitions Does this Loan Fall Under Reg U? Adverse Action -What Reason Do We Give for Denial? HELOC Documents Special Information Booklet and Refinancing Reg B - Father & Son Joint Applicants Auto Debit Loan Pay - Signature Required? Swimming Pool Loan Considered Home Improvement? Who Completes the HUD 1? Cash Out Loan - HMDA Reporting Participation Loan Record Retention Securing Debt Payment HMDA Reporting - Multiple Advance Open Ended LOC Perfecting Interest in Federal Receivables RESPA Bridge Loan Exemption Automatic Rate Change - Mail Out Notice? Dating the Application Divorce & HELOCs Mobile Home Flood Insurance - Guru Q & A Follow Up HMDA Reporting - Home Purchase w/CD as Collateral Trigger Terms on Rehab Loans Extending a Balloon Loan - Disclosures Required? Online Calculators Separate Loan Apps for Unmarried Co-borrowers? Reg B Form Signed on Commercial Credits? HMDA Reporting - Office Isn't an Official Branch Insurance Disclosures on Business Purpose Loan Security Interest in a Savings Bond Refinance New Note with No New Money - ROR? ROR on Second? Title Held by Husband Only - Must Wife Sign ROR? Collect Applicant Info on Non-Reportable RE Loans? Special Information Booklet Via Weblink? Credit Report - Written Authorization Required? HMDA - Extending a Current Obligation GMI on Refinance Financing Differences Refinance of Primary Residence - Collecting GMI PMI Disclosures on Non-Owner Occupied Property HMDA - Non-Reportable Bridge Loan? Home Construction Loan - RESPA Applicable? Cost of Undisclosed Debts by Borrowers to Lenders The HUD-1 and Lender Credit Flood Insurance - Uninsurable House Signing the Co-Signer Notice Assignment of Mortgage - New Note Needed? Denying Credit Based on Non-Citizenship Flood Force Placement Notification Letter Requesting Copy of Credit Report Pulled at Bank Mitigating Mortgage Fraud: Application and Other Misrepresentations Protecting Against the Credit Card Crisis Foreclosures and the effects of the subprime market Examiner Verification of RCV on Comm Property Purchasing a Home on Contract - ROR Required? HMDA & Reg B - Temporary Financing? HMDA Reporting - Commercial Loan Refinance 401K Loans Business & Farm Loan Renewal Fee Equity Line of Credit – Funds Disbursal Tying a HELOC to the Prime Rate Regulation Z - Phone Inquiries Pulling Credit Bureau Report - Customer Notice Certified Real Estate Appraisal Required? RESPA Applicable to a Consumer Installment Loan? Business Purpose HELOCs? HELOCs Without a Maturity Date? Web-Based Lending Reg O - Aggregate Lending Limit Is a Faxed Signature Legally Binding? Portfolio of Lending Products for SMBs HOEPA Rate Spread Amounts Is the "Individual" a Consumer or a Business? Removing Ex-husband from the Loan Automated Underwriting System - HMDA Reporting Credit Denial Form Dating Flood Research Data Calculating the Aggregate Adjustment About the Community Reinvestment Act Hunting Camp - HMDA Reportable? Lowering Rates on Existing Mortgages - Redisclose Flood Compliance & Master Certifications ROR Needed When Changing a Rate on Note? Risk Monetization Obtaining Credit Bureaus for Our Auto Dealers Mobile Home Late Fees Roll Attorney's Fees into First Mortgage? Mortgage Rate Lock Fee 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 Unsecured Legal Lending Limit for National Banks 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 File a SAR on Levied/Garnished Customer? Authorized Signer Avoiding a Levy or Garnishment Bank Execution Against an Individual IRS Tax Levy - Funds Less than Amount Levied Levy on Account Receiving SS Deposits Levy the IOLTA Too? Are We Aiding Customer in Avoiding a Levy? Notice of Levy Extends to Loans, Too? Child Support Enforcement Levy Tax Levy or Garnishment on a IRA Account Reg DD - Garnishment & Levy Fees Garnishments and Levies (PDF) Levy on Pledged CD Can We Collect Our Fees Before Paying a Levy Service of Tax Levy or Garnishment Papers > Can a Levy Access a Line of Credit? Levies on Dormant Accounts IRS Levies, Primary Accountholders, and Beneficiaries
Can we place a hold on VA benefits when we received a levy? Levy: Do we use the balance at the beginning or at the end of the day? State Tax Levy On An Individual: Which accounts do we charge? Personal Tax Levy & Business Account Social Security Deposites & Levies Tax Levies & CDs Lien HMDA Reporting – Loan Secured by Lien on Dwelling Funding on Warehouse Lines of Credit Vehicle Lien Filing Fee Is a Chattel Mortgage Always Required? Lien Position on Loan Secured by CD Taking a Deed of Trust as an Abundance of Caution Servicing Transfer Notice Documentation for "Abundance of Caution" Liens Which Takes Priority, the Levy or Lien? Does the Spousal Signature Rule Affect Perfection? Purchase Money Loan for Wedding Ring First or Subordinate Lien? UCC Filing Required on Mobile Home Loan? Perfecting a Lien on Aircraft Advance To Debtor After Guarantor's Bankruptcy Upheld What if a lien is mis-filed? Renewing A Collateralized Loan: Do we have to re-file the lien? Limited Liability Company (LLC) HMDA - Data Reporting Owner Occupancy LLCs & Right of Survivorship Titling an LLC With a SSN CTR - Separate Deposits in Same Owner LLCs Improper LLC Endorsement? LLC Account Opening SSN for a Single Member LLC? LLC Owned MMDA HMDA Triggering Loan LLC with a POD? Two Separate LLCs, Same Owner & Same EIN Business LLC & DBA - Two Separate Entities? Now Account Owned by LLC - Options & Penalties Remove Incarcerated Member from LLC Account? Residential or Commercial? LLC Ownership of a Money Market Deposit Account LLC & LLP Loan Documentation LLC Certificate of Formation LLC Documentation - Adding or Removing a Signer Changing from Sole proprietorship to LLC Borrowing on Home Owned By a Business LLC Client Doing a HELOC on Personal Residence LLC Acct Overdrawn By Director, Reg O Violation? Should We Allow Cash Back on LLC Deposit? Power of attorney and LLC POD on an LLC LLC Owning an Interest-Bearing Account LLC Using a Social Security Number Proper TIN for LLC
LLC Accounts: SSN or TIN? LLCs and NOW Accounts What types of accounts is a LLC allowed to have? Can an LLC be liable for the debts of its sole member? Living Trusts Restyling Revocable Trust After Spouse Dies Make Cashier's Check Payable to Customer or Trust? Living Trust - CIP the Beneficiaries? Living Trust.. SSN or EIN? Step Children as Qualifying Beneficiaries Sufficient Information for CIP on Revocable Trust Reg E - Debit Card for Trustees of Living Trust Who is the Owner of a Living Trust Account? Signers on Trust Accounts Can this Trustee Resign? Authorized Signers on Trust Accounts Living Trusts & POA Leasing a safe deposit box to a trust Classification of Trust Account TIL Disclosures for Loans to Trust A HELOC for a Living Trust? Adding A Living Trust As POD Can a living trust have a NOW Account? Does Reg Z (Rescission, or Sec 32) apply to a "Living Trust"? Right Of Rescission & Living Trusts Using SSN As TIN For A Irrevocable Living Trust?
Loan To A Living Trust: Required Documentation Home Equity Loans For Property Owned By A Living Trust Living Trusts & Sole Proprietorships Loan Application Reg B – Listing Order of Applicants The Equal Credit Opportunity Act Reg B - Completed Applications Fair Lending Mortgage App and E-SIGN Web Application Applications Online Collecting GMI on Loans Not Reported on HMDA LAR Reg B - Application Signed With a "Courtesy Title" Reg B - Dual Signatures Must GMI be in Customer's Handwriting? Reg B - Business Credit Joint Applicants Streamlining the Loan Coupon Process Reg B Inquiries CRA Branch Notice Requirements Correcting the Applicant's GMI Applications - 3 Day Disclosure Period Monitoring Information - Co-applicant not Present Notice to Home Loan Applicant Disclosure Loan Denial Based on Net Worth
Selling Mortgage Applications Appraisal Fee Refund & Notice OFAC Check on Seller of Property Pre-approval Confusion Fact Act Letter Lender Signature Required on URLA? Loan Denied to Illegal Alien- Adverse Action? Notice to Home Loan Applicant Disclosure Application Withdrawn if Documents are Signed? Reg B Loans - Retirement Contributions as Income We Don't Report HELOC's Under HMDA, However... Credit Life Financed on Home Loan, GMI Required? Co-Signer/Guarantor Notice after Denial Reg B - Intent to Apply for Joint Credit FACT Act - Forms, Timing of Notices & Disclosures FACTA Confusion - Sharing Information w/Affiliates Disclose "No Purchase Necessary" in Sweepstakes Ad 88 Year Old Applying for a 30 Year Mortgage Another Joint Application Question Sending Out a Commitment Letter
No Loans to Non-US Citizens, Disparate Treatment? Declining a Joint Application Can It Be Either/Or? HMDA (PDF) Lending referrals Dual Monitors Vs. Full Screen Applications Denying business credit: written or oral notice? Do We Now Need Business Loan Applications? Bare-bones Application Checking Applicants and Signatures Reg B Application Requirements Joint Applications/Loans Sold on Secondary Market Form 1003 -- Residential Loans Only? Electronic loan processing question 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 Loan Files Adverse Action- File a Copy of the FCAI Disclosure BSA Retention Policy & Loan Documents Rescission & Loan Doc Date Dilemma Must TIL Disclosure be Signed & Kept Filed? Signing for Disclosures Boat Loan Documentation CIP Proof in the File Renewal Notes Signed TIL Missing from Credit File Copy of Green Card in the Loan File Motor Vehicle Titles Copy of Drivers License in the Credit File Copies of IDs in the Mortgage File, Yea, Nay? Legalities of Copying a Driver's License Signed Affidavit Stating Customer Won't Escrow? Keeping Employee Credit Reports in a Separate Loan File Inspections Are Good. Repeat. Transfer of Servicing Notice Signature Requirements Checking Applicants and Signatures Lending Efficiencies in a Changing Rate Market Reg. B -- Withdrawn Application Copy of ID in Loan File OK? Documenting the Loan Retention Period on Home Equity Loan Files Altering Collection Notes Retention Period on Home Equity Loan Files
Retention Period For Lending Documents
Documentation: Necessary For Everything Denials, withdrawals, or incomplete applications Disclosures: Single Acknowledgement Form or Individually Signed Disclosures? Auditing loan files Reactivating a loan file as a result of a new application Loans Business Purpose Loan - RESPA Applicable? Reg B – Listing Order of Applicants Looking for a Cure HMDA - Data Reporting Owner Occupancy HMDA Re-file ARM Loan - No Adjustment Schedule Flood Map Revision The Equal Credit Opportunity Act Reg O – Sold Loans HMDA Reporting – Dwelling Used for Day Care GMI Collection – Purchase of Primary Residence Fair Lending Advertise a Discounted Loan Payment Reg B - Completed Applications Flood Insurance & Mobile Homes Flood Map Revision Purchase Money Home Loan Refi – ROR? HMDA LAR - Boat Dock & Lake House Purchase Loan Guaranteed, Not Cosigned – Compliance Issues? Mortgage Relief Scams Credit Score Disclosure -Interim Construction Loan Government Monitoring - Absent Joint Applicant Business Loan Denial Notice Premium Disclosure Real Estate Lending & Trusts Loan Rate for Army Reservist ECOA Applicability - Joint Vs Individual Credit Confirmation the Appraisal Notice was Provided Appraisal Rules Point & Fee Test or APR Test? HMDA – Which Date Do We Use? Condo Flood Coverage All Signers Sign the ROR? ROR on RV? Home Mortgage Refinance - Flood Search Required? Disclosures Within Three Days of Credit Report Reg O & Executive Officer Account Signer Quarterly CRA Reporting - Updated Income Levels Bank Debiting Account after Loan Charge Off General Interest Law v UCCC Loan Sold to Investor - Borrower Closing Costs Loan To Cost Guidelines Flood – Loan Secured by Leasehold Mortgage Refinancing for a Better Rate – ROR Applicable? General Interest Law v UCCC Listing Reason for Denying Loan Applications Land Only Loans - Early Disclosures Required? Change in Terms Agreement Definition of Permanent Takeout Commitment Needed Real Estate Transaction Fees TIL Disclosure Statement - List Fees? Reg Z - Lot Loan to a Family Trust New RESPA Rules - Tolerance for Fees RESPA – Compliance Vs Lender Revocable Living Trust & HMDA LAR Reporting Flood – 45 Day Notification/Waiting Period Flood Certification Frustration Flood Determination Request Loan to LLC Sole Owner - HMDA or Purchase Money? Lending & the E-sign Rule Curing a ROR Notice Violation Reg U - Purpose Loan Vs Non-Purpose Loan HMDA – Loan Coded as Business/Residence Combo ROR on Mortgage & HELOC Closing Simultaneously Handling the Interest on a Loan Renewal CRA - Logging Company a Small Farm Loan? CRA Reporting - Small Business/Small Farm Loans RESPA – Short Term Loan Fixing HOEPA Violations Commercial Loans – What’s HDMA Reportable? Reg Z - Inspection Fees in the Finance Charges HMDA Reporting – Mixed Used Property Loan Do a Flood Determination for Each Property? Combining Loans – Does ROR Apply? Origination Fee Discrepancy Adding Spouse to Open-End HELOC Secondary Market Loans Acquired HELOCS - Change in Terms CRA Loans & HMDA Logs Loan Modification – HMDA Reportable? Reg B – Joint Credit & Cosigners About the Making Home Affordable Program Three Year Balloon Mortgage Owner Occupied Second Homes & Vacation Homes HOEPA & Bridge Loans Signer Pledging Interest - Appraisal Notice Given? Business Loan Partially Secured by Residence –ROR? ODP Via a LOC - Annual Financial Statement Reg B Intent to Apply Jointly – Phone Application Disclose Fees Borrower Doesn’t Pay? Reg Z - Website Disclosures Reg Z Reimbursement Procedures GMI on Refinance Q & A - Clarification Needed Disclosure Differences Online Mortgage/ARMs on the Web FHA Loans - Referral Fees POD Account as Collateral on Loan Funds Disbursed Prior to ROR Date Renegotiating Indefinite HELOCs Refinance Denied – Send Adverse Action Form? Mobile Home Loan a Residential RE Transaction? Reg O - Bank Holding Company Chairman PMI - Send Out Amortization Schedule Creditor Challenges with Small-business Fraud Credit Verification Retention Resubmit Disclosures in Surviving Spouse's Name? Not Subject to HMDA Reporting – Collect GMI? New Servicing Disclosure Statement Form CTR on Closing Cost Down Payment No Flood Notice Given - Force Place Flood? RESPA - No Disclosures Required? Pay Bank Employees for Mortgage Loan Referrals Definition of a Restructured Loan Imposing a Default Rate of Interest on a HELOC Reg Z - Open End Credit Line Increase Duplex Refinance Disclosure Required on LTV Ratios Change? Sending Email Ads to Selected Brokers New TILA Pre-Disclosure? Red Flags Rule – Small Business Loan Requirement? Calculating Exposure to Payment Card Industry (PCI) Standards Protect Against Small Business Fraud Guidance Needed on TIL Disclosures Credit Bureau Reporting – Advance Notices Overdrafts Covered by HELOC RESPA -Residential Lot Loan Secured by Residence Freezing an Unsecured LOC – Notice Required? Mobile Home as Collateral – Do a Flood Search? Balloon Loan - RESPA Disclosures HMDA Reporting – Loan Secured by Lien on Dwelling Force Placed Flood – Notification Loan to Company - Director is Shareholder Independent Appraisal – Notice Still Applicable? CRA - Loan to Deposit Ratios ROR on HELOC Renewal? Fair Lending - Income Verification HOEPA - Minimum Loan Amount Reporting Question Types within Knowledge-Based Authentication Credit Life/Disability Insurance Program Denied Loan Retention Schedule Commercial Loan to a Sole Proprietorship LTV Reporting Rule HELOC Rate - Floating or Fixed? Percentage of Exception Loans Changing LTV Ratios Timing of GFE HMDA Reporting - Closed-End Lines of Credit Preliminary TIL No Longer Required? HMDA Log - Order Information is Entered Loan Privacy Policy Documents Loan Denial - Census Tract Number Forty Year Mortgage HOEPA Test Risk Based Pricing Model – No Historical Data File a SAR on a Loan Officer? Purchased Loans - OFAC/USA Patriot Act Compliance HMDA Reporting - Modified Construction Loan GMI Data on Commercial Loans Higher Priced Mortgage Loan Rules HUD 1-A Form Line 1604 Mitigating the Risk of Never Payment Portfolio Types that Experience Never Payment Loan Sign Advertising Compliance New Auto -Loan - First Payment 90 days Never Payment and Fraud Type Flood Certificate – One Time or Life of Loan? Employee Loan Policies Question the Purpose of the Loan? Unsecured Legal Lending Limit for National Banks Car Dealer Indirect Loans – Application Process Not a HMDA Reporting Bank - URLA Required? Corporate Loan Regulation Never Payment Capturing Never Payment Behavior CRA Branch Lobby Notice Bank Querying Customer on Age & Retirement Plans RESPA - Non-Borrowing Owner Sign Initial TIL & GFE DIC Insurance Policy In Lieu of NFIP Policy? Provide Copy of Appraisal on Commercial RE Loans? Purchase Force Place Flood Insurance on Day 46? HMDA Reporting - Swimming Pool Secured by Dwelling Flood Insurance – Bank Owned Collateral Property Carrying Out a Bust-Out Scheme Bust-Out Targets The Latest Fraud Trends and Solutions Adverse Action- File a Copy of the FCAI Disclosure Flood - Life of Loan Certification Coverage RESPA – Title Company Broker Fee 15 Year Historical Example on a HELOC Disclosure Interest Incorrectly Documented on Consumer Loan Converting Closed-End to Open-End Credit Loan to Entity - Demand Clause Required HMDA - Double Reporting? Gifts to Top Loan Customers HMDA – Repurchase of Loan Co-Borrower Added - Provide New Early Disclosures? Deed of Trust as Collateral – Give ROR? Co-Borrower Added - Provide New Early Disclosures? Multiple One Month HE Loan Extensions Business Purpose Statement Form Shares of Bank Stock as Collateral SCRA – Report Delinquent History on Credit Report HMDA – Report as a Purchase or Refinance? RESPA - Rental House Refinance Flood Determination Date & ROR Paying Tellers a Referral Fee – RESPA Violation? Vacation Home Subject to HUD’s Reg X? Internet Based Loan Applications Tainted Appraisal? Co-Signer Required to Sign the Notice? SCRA – Is 6% the Interest Rate or the APR? Additional Funds to Complete Home Construction ESIGN or UETA Mandatory Flood Coverage on All Buildings? Business Purpose and Exempt from RESPA? Loan Secured by Son's Home - HMDA Reportable? HMDA Reporting - Selling a Participation Loan Business Purpose Statement Disclosing PMI Provider Collateral Mortgage on Parent’s Residence - ROR? Definitions Needed 90 Days for Non-Accruing Interest Rule Borrower Discontinues Loan Application Flood Insurance Rules & Commercial Condos Revolving LOC Secured by CRE with a Low LTV Obtain New Flood Determination at Extension? Hold Car Title as Collateral Against Charge Off Delay Disclosures Until Completed Application? Reg O Reporting - Standby Letter of Credit GLBA and Customer Information Lending Office Issuing Cashier's Checks Reporting Rules for Open-End & Closed-End LOCs SCRA – When Does Active Duty Begin? Flood Insurance - Additional Premium Owed Construction Loans & Section 32 Guidelines CRA LAR – Coding Group Homes SCRA – When Does Active Duty Begin? Flood Insurance - Additional Premium Owed Construction Loans & Section 32 Guidelines CRA LAR – Coding Group Homes ARM Disclosure - Table Not Required? Banks and the Servicemembers Civil Relief Act (SCRA) Collateral & Purpose Codes Travel Trailer as Added Collateral on Lot Loan Classifying Farm Land for LTV Purposes Equal Housing Lender Sign - Latest Version Combining a Consumer & a Commercial Loan Please Define RCBAP Teller Cross Selling Training Advertising - Loan Amount & Calculating APRs Loan Officer is a Realtor - A RESPA Issue? The Temporary Liquidity Guarantee Program (TLGP) Shutting Down a Revolving LOC – Compliance Issues Reg O – Participation in Major Policy Making No Customer Response - Send Another Action Notice? HMDA Reporting on Entities Update Existing & Merged Customer CIP Information Timing of Early TILA Disclosure Reg B & Business Loans Balancing Risk and Reward The Great Debate: Credit or Public Records Data Reg R Section 218.701 Compliance Adverse Action Notice - Calendar or Business Days? FDIC Ruling Applicable to Commercial Loans? Entitled to SCRA Relief? Non-Borrowing Spouse Signing TIL & RTC Forms Mobile Home on Property – Loan on Land Only HELOC - No ROR Required? Statement Stuffer Loan Ad – APR Disclosures Loan APR Discount Purchased Note - Treat as Refinance? Is the Assumption a Refi or Purchase Purpose Loan? About the Housing and Economic Recovery Act Adverse Action - Ex is Only Source of Income Reg D – Internal Transfer Loan Payments Is This HELOC Renewal Considered a Refinance? Assumable Mobile Loan - Which HUD Form Do We Use? HELOC Secured by a Second Home OCC WIN Calculator - Odd Days Interest Update Original Reports & Use the Same Appraiser? Broker Required to Send Servicing Disclosure? Commercial Loan ARMs? HOEPA - Combined Transaction Loan Property Deemed to be in the SFHA Disclosing Vendors Used in a Mortgage Loan Appraisers & the GFE App Withdrawn/Denied - Collecting an Appraisal Fee Reduce Interest on a Loan - Modification Needed? Reflect All Fees on HUD Prepared by a Title Co? My Home Is & Isn't in a Flood Zone HELOC Suspension Letters - 202.9 Requirements Adverse Action - Separate the Reasons for Denial? Reg B, HMDA & Pre-Approval Letters Bank Failures, Uninsured Deposits & Loan Payments Flood Zone Change & the Grandfathering Rule Loan with an ROR - Date Interest Accrual Starts Son Taking Over Deed & Debt Customer Refuses to Pay Escrow HMDA Reporting - Use Original Lock-in Date? Retention of Declined Online Credit Applications Must We Redisclose Thousands of HELOCs? Are We Required to Get Marital Status on Loan App? ROR on Loan to Move a Home Holding Check in Escrow During Rescission FDIC and Loan Ad Houseboat Purchase - HMDA Reportable? Only Current Customers Eligible for Credit? Federal Credit Application Insurance Disclosure Reg B - Separate Apps for Joint Borrowers? Balloon Loan Modification Disclosures Reporting HMDA Data to the Board HELOC Modification Or a New Loan Required? Seller Paying Fees Due at Closing Advancing Funds on a Matured Line of Credit Financing provided by... Required/Optional, Member FDIC Rate History Disclosure Disclsosures for a Complete App with a Property Federal Credit Application Insurance Disclosure Notice to Home Loan Applicant Required? Maximum Number of Reasons for Declining a Loan RESPA on Rental Homes Change in Terms, No New Money, ROR Needed? Disclosures to Father Who is Loan Co-Signer Minor Auto Loan - Parent is Co-borrower Providing Loan Disclosures - Maximum Time Allowed Increasing Interest Rates on Past Due Loans Houseboat Loan - Residential or Consumer Loan? Full Amount of Fee as Prepaid Finance Charge Reporting Non-Mortgage Loans under HMDA HMDA - Swimming Pool Loan Secured by Automobile Reverse Referral Fee Loan Rate in Advertisement Verifying Information for Loan when the Credit Report is Obtained Reporting Loan Accounts and New Deposit Accounts Reconciling Addresses on CRAs for Loans ARM Product Disclosures Manual Underwrite Recommendations Bridge Loan Extension- Early Disclosures Required? We Don't Do HMDA Reporting - Do We Collect Info? Reg Z Advertising Penalties Commercial Loan Referral - Paying a Finder's Fee Flood Zone - Must Determination & Policy Match? Spouse Not on the Loan - Collecting Spousal Info FDIC Loan Definitions Adverse Action -What Reason Do We Give for Denial? Listing Taxes on RESPA Forms Tax Holding Fee - Part of the APR? Does this Loan Fall Under Reg U? Reg B - Father & Son Joint Applicants Auto Debit Loan Pay - Signature Required? Swimming Pool Loan Considered Home Improvement? Participation Loan Record Retention Who Completes the HUD 1? Cash Out Loan - HMDA Reporting RESPA Bridge Loan Exemption Clarification Needed for Prequalifications HMDA Reporting - Multiple Advance Open Ended LOC Calculating Flood Insurance Reg O - Extensions of Credit in the Aggregate RESPA Bridge Loan Exemption Automatic Rate Change - Mail Out Notice? Dating the Application Loans Contingent on Account Ownership Taking Phone Loan Applications - Compliance Issues Reg Y - Foregoing the FIRREA Appraisal Divorce & HELOCs Mobile Home Flood Insurance - Guru Q & A Follow Up HMDA Reporting - Home Purchase w/CD as Collateral Online Calculators Extending a Balloon Loan - Disclosures Required? Trigger Terms on Rehab Loans In-house Lobby Flyers - Disclosures Required? Separate Loan Apps for Unmarried Co-borrowers? Reg B Form Signed on Commercial Credits? HMDA Reporting - Office Isn't an Official Branch Collect Applicant Info on Non-Reportable RE Loans? Security Interest in a Savings Bond Refinance New Note with No New Money - ROR? ROR on Second? Title Held by Husband Only - Must Wife Sign ROR? HMDA - Extending a Current Obligation GMI on Refinance Financing Differences Refinance of Primary Residence - Collecting GMI PMI Disclosures on Non-Owner Occupied Property Disclosing Loan Rate as Prime Denied Loans Exempt from Early TILA? Joint Applicants - Separate Adverse Action Notices Flood Certification Loan Docs Mailed - Extending ROR Period Flood Insurance - Conflicting Zones RESPA - Prospect List Provided by Title Company 1098 Reporting - Loan in Non-Accrual Status Newspaper Loan Closing Coupon - APR & Disclosures Flood Penalties Spanish Mortgage Loan Disclosures A Few Dollars More? HMDA - Non-Reportable Bridge Loan? Home Construction Loan - RESPA Applicable? Cost of Undisclosed Debts by Borrowers to Lenders The HUD-1 and Lender Credit Flood Insurance - Uninsurable House Signing the Co-Signer Notice Assignment of Mortgage - New Note Needed? Denying Credit Based on Non-Citizenship Loan Message on Statement – EH Logo Required? Mitigating Mortgage Fraud: Application and Other Misrepresentations Protecting Against the Credit Card Crisis Foreclosures and the effects of the subprime market HMDA Reporting - Commercial Loan Refinance HMDA Reporting - Loan Secured by Apartment Building 401K Loans Use of Evaluations in Lieu of Appraisal Equity Line of Credit – Funds Disbursal Tying a HELOC to the Prime Rate Bridge Loans & HMDA Bank Flyers at Dealership & RESPA Referral Fees MARI Releases the Tenth Periodic Mortgage Fraud Case Report RESPA & Vacation Homes ARM Loan TIL Disclosure Determining Amount of Flood Insurance Required Dispute Over Flood Zone Location ROR on Second Trust Deed HELOC Loan ROR Triggered by "Left-Over" Cash? Modification Fee - New Disclosures Required? RESPA - Kickbacks & Mortgage Broker Fees Mobile Home HELOC Customer Rescinded the Loan Web-Based Lending Mortgage Loan Changes - Redisclose the Loan? HELOCs Without a Maturity Date? Reg O - Aggregate Lending Limit Is a Faxed Signature Legally Binding? HMDA Reporting - Commercial Loan Refinancing Portfolio of Lending Products for SMBs Removing Ex-husband from the Loan Automated Underwriting System - HMDA Reporting Credit Denial Form GLBA Violation-Loan Info Displayed on File Cabinet RESPA - Short Term Loan Appraisal Requirements in the Construction Phase C and I Loan - Signed W-9? HELOC Modification - Extending the Draw Period Referral Fee to Customer Avoiding Bankruptcy Calculation of Fees Subject to HOEPA Roll Attorney's Fees into First Mortgage? Mortgage Rate Lock Fee Lowering Rates on Existing Mortgages - Redisclose SMB Loan Portfolios Deposit Account Required for Loan Approval? Collecting GMI on Loans Not Reported on HMDA LAR Flood Insurance Coverage Conundrum Independent Underwriter Appraisal Review RESPA - Loan on the Land, Not the Mobile Home Mandatory Purchase of Flood Insurance Selling Consumer Loans - Notices Required Business Loan Disclosures Document Needed for HELOC Extension Late Payment Charges Paid by Escrow Funds Risk Management with Small and Mid-Size Businesses Provide Rescission Period to the Borrower? HMDA - Recouping Home Improvement Costs Loan Modification Procedures Temporary Construction Loan - Does HMDA Apply? Loan Consolidation Deposit to Loan Ratio 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 Reporting on an Application Withdrawn/Closed Loan ROR Applicable on a Fed Reserve Holiday? Effect of Interest Rate Calculation Change Paying Off Late Fees with Escrow Account Funds HMDA -Short Term Loan Refinanced for a Longer Term Radio Advertising Disclosures Lending DDA Funds Construction Loans & Reg B Monitoring Information Commercial Loan Insurance TILA Signed by Non-borrowing Spouse Loan Funds Disbursal Mobile Home Loan Default - Demand Letter Crediting the Aggregate Adjustment Home Improvement Loan - Interest Paid Deductible? Loan Renewal & Mortgage Modification Trigger Terms Disclosure of HELOC Early Termination Fee HMDA - Define Temporary Financing HOEPA 2008 Threshold Amortized Home Improvement Loans Commercial Loan - HUD Settlement Statement? Section 32 Loans - Fee Trigger Threshold? Rate Lock Effect of Customer Pulling Credit Report Consumer Loan and Cosigner Procedures Executive Officer's Loan - Demand Clause Required? IRS Reporting - Payments to Lawyers & Law Firms Rescindable Loan & Amount Rescindable? New Security Agreement Required? E-Sign Tax Service Fee Exempt from RESPA Disclosure? Returning Paid Loan Documents to 401(k) Borrower CSDS Provided Prior to Closing? In-house Appraisal Based on a Tax Assessment Loan Commitment Required on a Mortgage Transaction Flood Insurance Coverage - No Appraisal Biweekly Mortgage Payment Agreement Reporting CD Secured Loan on the LAR Adverse Action - State Loan Amount on the Notice? Skip Payment Plan Definition of a Complete Application Co-signer Added – Joint Application Created? Adverse Action - State Loan Amount on the Notice? Send Loan Denials to Applicant & Guarantor? Documents Signed by Non-borrowing Owner Limitations on Late Charges Reg O - Defined Marketable Collateral Potential Sub-prime Lending Disaster ROR on Refinanced Loan BOD's Loan Modification Flood Letter Not Furnished Statement Stuffer HMDA Triggering Loan CD Secured Loan & the LAR HOEPA Worksheet Completion HUD Form - Bank's Responsibility Determining Builder's Risk Coverage Flood- Force Place Per Customer's Request? Application Denied - RESPA Disclosures Given? Reg B - Unmarried Couple Borrowing Jointly Gift Cards for Loans Paid in Full? Reg O - Waiving the 1% Origination Fee Application Withdrawn - Notice of Action Taken Notice of Action Taken - Retention Period URLA Required? Application Denied - Disclosure in File Flood Clarification Needed FACTA Applicable to Non-Consumer Loans? Loan Disbursal & Rescission Rights Credit Agreement Amendment GRMA Charging New Mortgage Wasn't Signed at Closing Loan to a Trust - Right of Rescission Help With an Abbreviation Making Quality Lending Decisions HMDA - Unsecured Loan Used as Down Payment Final TIL - Listing Names HMDA Reporting on Unsigned Loan Documents Balloon Disclosure Mortgage Late Fee Disputing ACH Debits on a Pay Day Loan One Loan for Two Properties - HMDA Reporting Oops! I Don't Wish to Cancel HMDA Reporting on an In-house Renewal HMDA Reporting- Dwelling Being Converted to Office Will Copies of the Initial Disclosures Suffice? Declined Loans - Required Disclosures? SSN on Credit Denial Does the Wife Have the Right to Rescind? Force Placed Insurance - Amount of Coverage Home Equity Reported on the HMDA LAR? CIP on Denied or Withdrawn Loan? CIP on Shared Loan Gift Cards for Loans Running OFAC on Loans Signing for Disclosures HMDA - Rate Spread Reporting ROR on Consumer Loan Paying Off Comm Loan Mixed-use Property Rules - HMDA Reporting Boat Loan Documentation Charge-off Amount on the Past Due Notices HMDA Reporting on an Unsecured Loan Ads with Balloon Payments Closing Money Laundry Suspect's Loan Account Mortgage Fraud Lender's Name Typed Not Signed on Mortgage Home Equity Loan on Construction -- Rescindable? Reissuing Right of Rescission Notices Phone Applications and Joint Intent Adjusting the HUD-1 Settlement Statement Home Equity Closed-end Loan Disclosures Reg B Appplication Violation? Adverse Action on Withdrawn Application? Joint Applicants - Separate Adverse Action Forms? Debtor's Privacy & Guarantor Notification Business Purpose Loan Disclosures FASB Documentation Fee Disclosure Commercial Loans - Required Disclosures HMDA Reporting - Loan to Purchase a Storm Cellar 1099 Required for Gift Check? Statement Stuffer Loan Secured by Stock Consumer Loan Underwriting Standards Flood Coverage - Loan Secured by Rent Houses Rental Property Covered Under TIL? RESPA - Personal Residence Construction Loan Regs Governing Comaker/Cosigner Notification Automating Your Fight Against Mortgage Fraud SCRA - Co-borrower Called to Active Duty Co-borrowers Liabilities & Credit Reports Home Value Determined by Tax Assessment? Application Withdrawn - Reimburse Appraisal Fee? No ROR Needed on Loan Renewal? Gift Cards for Loans Ag Loan or Home Loan? Guidance Needed on Late Charge Assessments Outstanding Interest Flood Coverage on Office Building Flood Insurance Application - Loan Closing Non-accrual Loans Farm Credit Loan Refinance - HMDA Reporting Obtaining Additional Flood Insurance Is a Chattel Mortgage Always Required? Can We Recycle this Appraisal? 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RE Loan with Two Single People Credit Report Run During Loan Pre-qualification Rider on an ARM Loan New Flood Certificate for Purchased Participation Loans Spouse's Access to Mortgage File Business or Personal Purpose Loan? HMDA Reportable or not? HMDA - Investment Purpose Loan Bona Fide Personal Financial Emergency? HMDA Reporting on Commercial Loans RESPA - Bed & Breakfast Loan Construction Loan Survey Fee Wedding Ring as Loan Collateral Send Stock to be Re-registered Form 1098 - Mortgage Interest on Rental Propery Loan not In SFHA - Monitor Flood-mapping Change? Signing a New SFHD Form for Remapped Property SCRA - Finalized HUD Notice Loan Scam Is there an advantage to tracking the performance of non-reported loans under CRA? Loan Denied Due to Cosigner's Bad Credit Margin Stock Land Purchase Loan - TIL Disclosure Loan Modification - All Parties Sign? Commercial Loan Advances PMI on Home Equity Loan
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HMDA - Transaction Secured by Other Dwelling Lien Position on Loan Secured by CD Bridge Loan Origination Fee Refund Loan Officers Prohibited from Ordering Appraisals? Correcting a Loan Closed at an Incorrect Rate Interest Rate of Loans Secured by Deposit Accounts HE Loans with Rates Based on Commitment Tiers Loan Reporting, Guru Follow Up 50 Mile Rule Giving Gifts to Auto Dealers for Loan Referrals Defining Temporary Financing, Then & Now HMDA Classification - Log Home Disclosures for Loan Secured by a Second Mortgage IRA CD as Loan Collateral Insurance Disclosures on Consumer Loan Mixed Use Building - Do Reg Z & Respa Apply? Loan Proceeds Disbursed Before the 3 Business Days Are We Required to Send Monthly Statements? Is the SCRA Rate Retroactive? Loan Declined Due to Customer Filing Bankruptcy Bridge Loan Disclosures Charging a Rate Lock Fee on Mortgage Loans What Defines a Business Loan? Small Business Loans Combined Consolidation Loan for Medical Bills Are Subprime Loans HMDA Reportable? Flood Certificates Is this Dual Purpose Loan HMDA Reportable? Twelve Month Waiting Period on Home Equity Loans Escrows & the Aggregate Adjustment Should We Change the Rate Instead of Redisclosing? Fee for Loan Payments Made with Credit Cards Note Date or Deed of Trust Filing Date? Are Ag Loans HMDA Reportable? Flood Insurance Coverage on Construction Loans Reg O – The Director Isn’t the Borrower, but ... CIP & Loan Participations Merging Required Service Providers on the Same GFE Discussing Loans with Father of Debtor, Privacy Violation? No Starting or Ending Date on the ROR Signing the New Note on a Loan Modification Primary Residence Secured by a Commercial Property Freezing the HELOC Account Reg B - Lending to Persons with Disabilities Do We Need to Re-disclose? Do We Need Early Disclosures? 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Record Retention on a Charged Off Loan Guarantor on a Commercial Loan to a Corporation Forwarding Declined Loan Applications to Mortgage Company Rate Change Notices on All Loan Types? With or Without Monitoring Information Keeping Photocopies of Sold Loans Secured by a Different Dwelling, HMDA Reportable? Bankruptcy - Re-scheduling Loan to Current Status Examples of Collection Letters HMDA Reportable? Disclosing Accrual Method on Commercial Loans HMDA - Which Date Do I Report? Determining Reduced Payment Amount under SCRA Conditions of Approval Unmet -- Action Taken Code Federal Regulations for Commercial Lending Customer Revised Loan Request Non-Filing Ins. in the Fed Box Credit Reports Documenting Delivery of Initial Disclosures
Negative "Amount Paid to Others on Your Behalf" Annual Financial Statement on Consumer Loan
Adverse Action Notice Without Reasons Limits on Commercial Loan LTV Ratios Determining Reduced Payment Amount under SCRA
Ex Officer Reporting Loans from other Banks Legality of Consumer Balloon Notes Is This What's Called a Pre-Approval? Balloon Notes and Title Problems Avoiding GMI Collection When Inappropriate Financing Vehicles With Salvage Titles Commercial/Residential Loan -- Consumer? Financial Statement on Another Bank's Forms Key Factors Disclosure with CRA Model
Flood Certification on Duplex With Two Street Addresses Is the Loan to spouse, a Loan to Ex. Officer, too? Primary Residence is an Income Producing Property Right of Rescission on Home Owned By LLC CIP on Business Loan Loan Fees & Late Fees (PDF) Loan Collateral & Security Interests (PDF) Mortgages (PDF) Finance Charge (PDF) Notice Given Only on Denied Loans? Are Variable Rate Disclosures Applicable? Appraisals (PDF) Flood Requirements (PDF) Extending a Note Via Modification Agreement HMDA -- Choosing the Property if More Than One HMDA Reporting & the "Short Term" Loan Collecting GMI From Non-Occupant Co-Applicant HOEPA Home Improvement Loans Curing Time for APR Disclosure Error on RE Loan A Fund That Gives Back Giving the Customer the WHOL? Preapprovals and Changes of Mind Tiered Loan Rates and FACT/FCRA Notice Do RESPA or TIL Cross This Bridge (Loan)? Negative Information Disclosure on Existing Loans Refinancing a HELOC as an ARM Limits on Texas HELOC Loan to Value? Admin Fee VS. Processing Fee Applications "Closed for Incompleteness" Rescission and Purchase in One Loan Second on Residence to Build New Home- Rescission? Mortgage Broker Looking for Answers Documentation for "Abundance of Caution" Liens Home Equity Loan to Revocable Trust Flood Requirement with Mixed Collateral Collecting the Correct Interest for Renewal No charge, no delivery of appraisal? Document Prep Fee in APR? Minister Purchases Houses to Renovate and Sell Verifying the Collateral Base on a Revolver Rescission Rights for Non-Obligated Owner? Consumer loan billing Differences and Definitions of Loans Is this Car Loan Subject to HMDA Reporting? Intitial Residential Mortgage Loan Disclosures Maximum Non-Taxable Amount for New Mortgage Bonus Starting Up a Loan Service/Admin Division A HOEPA or Not a HOEPA - How to Tell Number of HE Loans Allowed for Single Property CRA or HMDA? Do We Now Need Business Loan Applications? Does HMDA Apply to THIS Business Loan? Insider Report Requirement on Guaranty? Disclosures on Financing Sale of Repo Vehicle When Does A Loan Get Considered Delinquent? Wording on Adverse Action Notice Underwriting Fee Included As a Finance Charge HMDA Reporting for Broker/Lender HMDA on a Commercial Loan Can We Copy the Credit Report to the Broker? Does Reg O Apply to Loans on the Secondary Market? Open an Account & Reduce Your Loan Interest Rate Paying Past Due Taxes and Accruing Interest Paying RESPA Referral Fees Is a Renewal of Purchase Money, Purchase Money Grossing Up HMDA Income Advertising a Loan With a Prepayment Penalty Reg Z: First Mortgage Liens & Home Equity Loans Business or Consumer Loan Balloon Loans and HOEPA Terms BSA Record Keeping Requirements on Loans Define "Open-End" Credit Loans and Kickbacks Flood Insurance FCRA and Credit Reports Reg O - Mortgage Loans Sold to Investors Reg D - Telephone & Internet Loan Pay Transfers Is this a HMDA reportable loan? How is this coded for HMDA? Why Is A New Flood Determination Needed Loan Classification Triggers Do we need an application for this loan? Using your Information System to Improve your Loan Portfolio Stop Pays on ACH Pay Day Loan Payments Flood Insurance Waiving ROR on Refinance of Principal Residence RESPA and Fee for Services ECOA Requirements on Term of the Loan Disagreement on maturity dates Cross-collateral clause and rescission Record Retention for Imaged Loan Documents Titling a loan to a sole proprietorship Loans and Insurance Disclosures FACTA - Loans Based on Credit Scoring Trigger Timing of Adverse Action Letter on Mortgage Loan Free Phone Card - Getting a Referral In Return Reg B. Commercial Adverse Action Is This a Permissible "Quid Pro Quo"? Demand Letter Process Flood Notification Refinance or not? Will This Be an ARM Loan? APR on this loan? Small Business Loans Checking Account as Collateral for Loan Deposit Accounts as Collateral Avoiding The Rescission Period HOEPA Reporting Threshold HMDA Reporting on an Unreturned Loan Application Checking Account as Collateral for Loan Deposit Accounts as Collateral Record Keeping on Paid Loans Vacation Package in Exchange for Loan Referrals Returning paid documents Is This Servicemember Protected by SCRA? Do We HMDA a Loan for New Appliances? AA on Loan Application - 2 SARs Filed on Customer OFAC Checking of Loan Payments Purpose for Closed-End Home Equity Loan FACTA - Don't Report Negative Information on Loans Disclosing Mortgage Spreader Clauses Disbursing Loan Proceeds Before Borrower's Funds Reporting Loans to Credit Bureau Abundance of Caution Collateral & Flood Insurance Which HOEPA rate do I use? Two loans at closing - one HUD-1 Loan Interest Rate Discount for Automatic Tran Will Promo Open a Treasure Chest or Can of Worms? Early Disclosures for Bridge Loans Flood Zones, But Coverage Is Not Available Changing Late Fee on Existing Loans Reg B - Financing Insurance Premiums as Loans Loan Denial Notice Interest rates for servicemembers Signatures required on loan to partnership Is this prohibited discrimination? Dual mortgage origination structure--compensation Permitted fee for services? Loan on Spec Home - Disclosures? APR Explanation? Variable Rate Construction Loan Using Escrow Account Surplus for Delinquency Do We Need to Give Another Flood Notice? Rescission Rights on Mobile Home Loan Reg O and minority partnership interests The Difference Between a Loan and a Credit Sale Business Loan CRA/HMDA Reporting Advance Qualification of Loan Prospects? Refund of Rate Lock Fee -- POC? Flood Checks on Every Mortgage Loan? Can a Real Estate Agent Steer Clients Toward a Lender? Affording a Home in High-Cost Areas Long First-Period Mortgages APR Formula for Construction Loan Can Defaulted Loan be Modified? Must We Have a Rate "Cap" on This Loan? Is a Modification of This Loan Possible? News Release Compliance Issues - Loan Program Registering MSBs Police Presence Via Low Cost Mortgages Capitalizing Interest on Loan Renewal What actions should my institution take in order to expand our Assessment Area(s)? Don't Waste Money on Compliance Section 32 Loan Question Increase Your Profits with CRA CRA: Minimizing Reporting Errors Collecting GMI on a Construction Loan 1098 Reporting on Non-Accrual Mortgage Loan Days to First Payment -- Who Governs This? Are Loan Proceeds Payable To Others Rescindable? CIP Requirements on a New Loan Customer Lending More for Debt Servicing OFAC Requirements for Lenders Selecting reasons for declining loans Usury laws question Setoff with a wrinkle Life of Loan Designation Preferential Employee Loan Rates Web Site For Student Loans Consumer vs. Business Purpose Loans SCRA & Student Loans Additional funds for a construction loan and disclosures What is Active Duty for SCRA? Stop Payment on a Loan Disbursement Check Mortgage Rates Tied to an Employee Benefit Plan PMI on Construction Loans Setoff at the Teller Window Lending Efficiencies in a Changing Rate Market Loan Denials for Third Party Applications Balloon Loan Disclosures Disclosure of Construction to Balloon Loan Incentive Program for Audit/Cmpl/Loan Rvw CRA Investment Test ARMs & Rate Spreads Cooperative UCC Filing- Continuation OFAC & mortgage broker loans Guru Chatter on Advertising Loans(PDF) Dealing with a Reimbursable Violation Retaining I.D. in CIP loans Motel Loan HMDA Reportable? CIP & Purchased Loans Documenting the Loan Balloon Disclosure MPPP on a Non-Residential Condominium Attorney Selection Based on Who Is Paying Calculating APR on ARMs
Signature Requirement for UCC-1 Lien Release Timeline Making Loans to Illegal Aliens Birthdates for Loan Applicants Removing an Applicant, New Application? First Time HMDA Reporter Has Questions Temp Loan to Rehab Property: HMDA Reportable? Is a loan to a mobile home dealer for an individual mobile home reportable under HMDA?
About Business Credit Cards
Is a Home Equity LC HMDA Reportable? What is a Reportable CRA Loan? Industry Standard for Documenting Joint Apps
Wording for Consumer Loan Apps Finding a Census Tract Number Exception to LTV Ratio Classification of Doc Prep Fees Renewing loans, property improvements, and flood Advance Notice of Hazard Insurance Force Placement Additional Flood Insurance for Line of Credit Reg E Coverage of Automatic Loan Payments Can Bank Stock Be Collateral? 1-8 range loan grading system Can We Take A Qualified Annuity As Collateral? Second loan based on appraisal of first loan Is appraisal by certified appraiser required? Funding Loan After Borrower Rescinds Obligation to Fund Loan Timing for Checking OFAC on Loans ROR on Construction to Perm Loan CIP on Construction Loan HMDA Reporting for Bank That Sells All Loans Bank in Dark Ages Reg O Demand Clause Retention Period for Paid Off Loans
Early Disclosures on Construction Loans Loan Participation & Flood Requirements Limits on Loan Payment Extensions CIP and Guarantors
CIP Procedures, Guarantors, and Co-borrowers CIP & Purchased Loans Are your Internal Controls like Swiss Cheese?Part 8 Are disclosures necessary for a $1MM consumer loan? Purchase money open end line of credit? Is participant required to get a flood certificate Disclosure Requirements For Auto Debit Reduced Rate Loans Negotiated closing costs & no-closing cost loans Loans, Collateral, & Bankruptcy
Examples Of Using A Loan To Launder Money Bridge Loans & ROR
Calculating APR On Loan Renewal 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 Commercial Loans: Customer Copy Of Appraisal Required?
Can a commercial loan be made to a borrower if the proceeds are to be used for investing in an annuity? Modifying Secured Loans Real Estate Loan To Illegal Immigrant Limits on Consumer Loan Fees? Is a loan application always required? Pricing Loans Based On Credit Scores Loan Document Preparation Fee Issues Residential Construction Loan Notice Requirement Exceptions to Rewriting, Extending, or Re-Aging Consumer Loans Using Consumer Forms For Commercial Loans Sample Form For The Past Due Mortgage Loan Notice Forms For Loan Officers Can a federal credit union set a minimum mortgage loan amount? Increasing The Loan Amount For A Commercial Customer -- New Note? Compliance For Mortgage Brokers Is it necessary to report our commercial and agricultural loans to the credit bureau? Pre-nuptial Agreements, Real Estate, and Mortgage Loan Signatures Construction Loan Disclosures Guarantor vs. Co-signer vs. Co-maker Converting Construction Loans State Law Or Federal Law For Loan Fees Loan Review and Credit Risk Rating Using Average Costs For Loan Fees Is it illegal to charge a loan documentation preparation fee? Commercial Loan Prepayment Penalty Disclosures Disclosures For Auto Loan Promotions ARM Loan With Demand Feature ARM Loan Disclosures Loans For Those With Poor Credit Revising Loan Payments Based On Escrow Changes Construction Loan Compliance Loan Operations Training On A PC-Based System Loan Policies & Procedures Training Getting Clean Loan Files Timely Delivery of Paid Off Notes Correcting Misapplied Payments Take your loan office to the dealership Creating custom loan programs Using pivot tables to check up on your loan officers Massage your loan data with Excel Disclosure Requirements: Variable-rate Commercial Loans Commercial Requirement for an Itemization of Amount Financed Form? Take your loan office to the dealership Creating custom loan programs Using pivot tables to check up on your loan officers Massage your loan data with Excel Emergency Loan Programs For Employees Any Problems With "Skip-A-Payment" Loans Re-filing Liens on a Renewed Loan Can an individual have a demand feature on a loan? "Never Take Collateral You Have To Feed" Loan "Skip-a Payment" Plans Lobby Notice Funds Availability Notice – Font Size Requirements List of Notices to Post in Bank Looking for a Financial Disclosure Notice CRA Branch Lobby Notice Safe Deposit Boxes in the Lobby Reg DD - Posting Fee Change in Branch Lobbies Lobby Rate Board - Interest Bearing Products Reg Z Advertising Disclosure Rules For In-Branch Posters HMDA Lobby Notice Posting Signage Search Lobby Posters in an LPO of a National Bank Tiered Rate Savings Ad on Scrolling Sign Explicitly Mentioning the PATRIOT Act on Lobby Notices CIP Notices to Loan Customers Posting Base/Prime Rate in Lobby Lobby Notice Requirements Chart Lottery End of the "Student" Account Sweepstakes - Bonus? Enter a Drawing by Completing a Customer Survey Will Promo Open a Treasure Chest or Can of Worms? Grand Opening Drawings & Employees Credit Unions - Lotteries/Sweepstakes Snow Blower Raffle Ads, Credit Cards, and Illegal Lotteries National Bank Permitted to Sponsor/Hold a Raffle? Web Charity Auction Drawing Restricted by Age A Raffle with Restrictions Money Tree Promo Silent Auction Ask About our Accounts & Enter to Win a Trip Will Promo Open a Treasure Chest or Can of Worms? Enter Contest - Receive Bank Product Emails Am I Losing My Marbles? Johnny Appleseed Jr. Ecology Club Program Fundraising Raffle Prize Drawing Tied to Auto Loan Would This Be Considered a Lottery? Prize Drawing limitation Complete & Return a Survey - Enter a Drawing Would This Be Considered a Lottery? Check Card Contest Privacy and Drawings Advertising a Drawing - Rules & Reporting Posting Rotary Club's Charity Event in Lobby Naming Prize Winner in Customer Newsletter OTS Savings Associations & Lottery Rules Anyone Can Enter the Drawing......However Sign Up for Internet Banking - Enter a Drawing Golf Tournament Sponsorship Enter a Drawing by Making a Donation New Branch Opening - New Car Giveaway Revamping Our Refer a Friend Promotion Win Cash at the ATM Customers Drawing for a Bonus on Free Checking Disclose "No Purchase Necessary" in Sweepstakes Ad Give Aways and Drawings
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