10/01/2004
Question: If we can't get the appraisal completed within 30 days of taking the application, what should we do?
08/02/2004
Does the 3-day right of rescission apply to business HELOCs (using one's primary residence as collateral)? I was under the impression that rescission only applied to consumer transactions.
06/07/2004
Our new applications do not have the Notice of Right To Receive Appraisal Copy on the form. Do we have to use a separate form now?
03/01/2004
On January 31, 2004, we lost a fair lending legend. Warren Dennis was an individual who made a huge difference in the world of fair lending.
02/23/2004
Our practice is to give the customer their copy of the Real Estate Appraisal at the time of closing. Is it a regulatory requirement that we have the customer acknowledge receipt of this appraisal in order to document delivery?
01/19/2004
Are preliminary disclosures required on preapprovals when there is no designated property? Borrowers obtain full credit approval, subject to appraisal. Also on prequalifications, are disclosures required? These would be cases that there is no credit verified, only qualified at borrower's verbal communication.
01/19/2004
What required disclosures to you need on a HELOC ifthe main purpose of the loan is to purchase the borrowers' house? They are only asking for $40,000.00? Do you need an early truth in lending disclosure or early good faith estimate and any other early disclosures?
01/05/2004
HMDA Question. The secondary market division of our bank sells 100% of the loans it originates. We collect the application, arrange for the title work, order the appraisal, and we close the loan in our name with our money. Who is responsible for HMDA reporting? I know it is the entity that makes the credit decision. We have felt like the investor makes the credit decision and so they report the loans they make and decline. However, we send the adverse action notice. I am hearing from others that both report. It seems to me that if we are comforatble not being part of the credit decision, then we are not responsible for HMDA reporting of loans that eventually are originated or declined.
01/01/2004
We have been getting a lot of questions about whether different arrangements are permissible or violate RESPA. The world of mortgage lending has become incredibly creative.
12/01/2003
We saw it coming. When the privacy regulation was promulgated, the agencies had to set standards for notifications.