I have a customer who applied for a loan to purchase unidentified investment property (a house) at a Sheriff Sale. He did not have a specific property in mind but just wanted the money in case he found something he wanted. This did not involve a pre-approval. The collateral for this loan was his vehicle. The application was ultimately denied. I need to know if this is HMDA reportable? The purpose was to purchase an investment home using his vehicle as collateral (which would mean for lien status we would choose "not secured by a lien". When inputting this to our CRA Wiz program we came up with validity edits for lien status and loan purpose. Can you help us determine if this is or is not reportable?
Can you provide a list of required officer positions? Are these requirements listed in the regulations or are they simply suggestions? I'm trying to determine which officer positions are mandatory for compliance so I may pass this information on to Executive Management.
Is CRA purpose driven or collateral driven?
Are small business/small farm loans whose gross annual revenue exceeds a million CRA reportable?
We want to start offering OD LOCs to our customers on automatic approval based on the customers QualiFile score with ChexSystems. We do not want the customers to have to apply for this, but rather, offer them the product after we have run them through ChexSystems and determined that they are qualified. What type of disclosures do we need for this? Do we need to have wording on the checking account application stating that we will use the ChexSystems report for this? Do you have any examples that you can give me?
Our lenders have been meeting clients offsite more frequently (i.e. at their home or place of business). Since the customer may not enter our branch, how do we meet signage requirements for Regs such as Fair Housing, CRA, CIP, and Truth in Lending?
What are the rules for reporting Consumer Loans on Land for CRA purposes? More specifically, would you use the geo info of the consumer or the land being bought or refinanced?
For CRA, if you book a loan in Feb 2010 for $10,000 and then renew that loan for $15,000 in June 2010, you would report the $10,000 loan for February and then report the $5,000 new money for June as two separate loans. Does this also apply for HMDA with home equity loans? Would you report only the new money the second time? Would you only report one?
Is it a regulatory requirement for all bank employees to be aware of the location(s) of the main CRA Public File?
Do banks still have to maintain a CRA file? The statement is posted in main lobby and branch. If we need to have a file, what do we to have in it?