A question has come up in regard to public comments left on the bank's Facebook page. Would Facebook comments that relate to the bank's performance in helping meet community credit needs rise to the level of placing these in the bank's Public File?
Must we go through the formalities of an investigation and document what we’ve done such as paying provisional credit on claims that were made timely?
I have a question about a Closing Disclosure and the Disbursement Date on a no rescission loan with payoffs requiring funds from borrower received on the next day. Would we disclose the Disbursement Date on the CD as the same day as the closing date or the date we receive the borrower's funds and the actual funds are disbursed?
Is the cost of an elevation certificate a valid change in circumstance? The elevation certificate is not a requirement of the bank but it is a requirement of the insurance company. If we don't need to re-issue the loan estimate where should the fee be disclosed on the closing disclosure?
With the SAFE Act, how are we required to handle the NMLS number when an originator leaves before their loan closes? Does their number remain on the documents as they were the Loan Originator or are we required to use a different originator number even though they didn't negotiate the loan?