I once read something that stated the Equal Housing Lender logo (EHL) should be displayed anywhere a home loan application is received. Should a national bank have the EHL logo displayed on each loan officer/customer service desk where home loan applications are received or is the lobby poster sufficient?
Reg. B includes signatures or inititals of borrowers regarding joint intent. Is it necessary to have the borrowers sign/initial again when extending or modifying the original terms of the note? I am assuming no, since it is required at application, which has already been satsified.
The bank wants to give a gift under $25 for all customers who fill out applications for credit cards or loans. This promotion will be held at branches in certain areas, but not statewide. Flyers will be available at all the personal bankers' desks. What would be the compliance requirement?
We qualify loan applicants based on gross income. Our credit officer says that tax free income from SSI or VA Disability is the gross income and shouldn't be grossed up. I say the income is net and should be. Who's right? If we don't gross tax SSI up, are we discriminating?
Do all the compliance documents and applications need to be dated?
Marketing wants to advertise that we have instant approvals for online applications. In fact, we will look at the credit score and terms requested, but some applications will be told their request is pending or is referred to a lender for review. I'm not keen on this ad from a compliance perspective, but what can I say to back this up?
Will you explain the difference between a prequalification and a preapproval for HMDA, RESPA and OCC purposes?
Under Regulation B of the Equal Credit Opportunity Act, when applying jointly, we have to get signatures or an initial for the intent to apply jointly. What if it's a modification with a new application?
Our bank will be reporting Home Equity Lines of Credits for HMDA. Although we are not certain what the guidelines are for the loan amount, we understand we have to report only the amount intended for home improvements. For example, do we use the amount they draw at closing? Please clarify how to determine what amount to use.
Are there any changes being made to the application associated with the new RESPA changes?