We have a loan for $3,372,000 that is HMDA reportable and we are going back and forth on how this should be rounded. Do we report 3400 or 3372 on the LAR?
We recently switched credit bureau vendors. This vendor automatically includes the credit score disclosure exception notice with the credit report. We in turn provide this disclosures to those who apply for consumer credit. There are times when a lender will use a consumer report for a business purpose loan. If we provide the credit score disclosure exception notice on a business purpose transaction/application are we asking for trouble with examiners? Could we be subject to fines?
Can you add force placed insurance to a non-accrual loan that is well collateralized? State laws and the contract allow it for it.
Why can't we hold customers liable for carrying their PIN with their card?
I have questions that bother me when I dealing with a commercial real estate transaction where a residential property is taken as collateral. When does the Notice of Right to Receive a copy of an Appraisal apply? I have seen many different concepts in the internet regarding to dwelling: - A 1-4 residential property which is the borrower or guarantor's principal residence; - Any 1-4 residential property which is the borrower's principal residence, and it is going to be refinanced; or - Any 1-4 residential property taken as collateral in the commercial real estate transaction. I would like somebody clarify which is in compliance. I am in Florida if that matters.