This question is in regards to collection of demographic information in a face-to-face interview. The applicant checked Mexican under the Ethnicity section but did not check Hispanic or Latino. The loan officer checked Hispanic or Latino and answered "Yes" to "Was the ethnicity of the borrower collected on the basis of visual observation or surname?" Now we are getting validity exception V629. Should the loan officer have checked "No" to the information was collected based on visual/surname?
Is a notification required to the consumer after 'conditional approval' has been granted and the consumer does not respond back with the necessary information or documents?
Does the Joint Credit under Regulation B applies to a 90 day extension of an existing loan? We are only extending the maturity date to allowed additional time to analysis and review.
Regarding the new ECOA Valuation Rule that amends the appraisal provision of ECOA's Regulation B. Would it apply to home builders? I can't find anything in the regulation that it wouldn't.
Does the new appraisal rule under the ECOA apply to Home Builders?
Will the address of the CFPB be required on all ECOA Notices beginning on January 1, 2013?
Regarding Adverse Actions - Everything we see says we need to keep consumer ones for 25 months. Our compliance person, now says we need to keep them for 5 years because of the Consumer Financial Protection Bureau. Have you heard anything about this?
For ECOA purposes only is a mortgage lender required to have a loan application taken, processed and submitted to underwriting within 30 days so that an underwriter can issue a conditional approval? Please explain when the "30 days" starts ticking for the lender to issue a decision? Can a decision be made just from the 1003 or does a fully processed package need to be submitted?
Regulation B. Recent third party compliance audit stated that when we provide the applicant with 'Notice of Incomplete Application and Request for Additional Information' form, it must include the ECOA notice. If not, we were told that we must then send 'Notice of Denial' if we do not receive requested additional information from applicant. We disagree and feel that the 'Notice of Incomplete Application and Request for Additional Information' form without the ECOA notice is all that is required.
I'm not finding too much written about ECOA Section 704B (collect and report information concerning credit applications made by women or minority-owned businesses and by small businesses). Has there been a guidance about how to collect the data, what form to retain it and how to report it to the CFPB?