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LAR Late Payments/Charges/Returns/Fees Legal Opinions Legislative Moves Lender Liability Lending Lending Limit Letter of Credit Levy Lien Limited Liability Company (LLC) Living Trusts Loan Application Loan Files Loans Lobby Notice Lottery 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 Prequals Under HMDA Reporting Small Dollar Withdrawn App Guru Chatter on HMDA/HOEPA Lien Status Reporting Under HMDA HMDA Help HMDA: Final HMDA Rules for 2004 Under the Revised HMDA Regs Funding Institution or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?