We are going to open a loan production office and need guidance on what types of signs need to be in the lobby. I'm thinking only the Equal Housing Lender Poster, but not sure. We are not taking deposits, and we are not a HMDA reporter.
Can I take partial counties for my Fair Lending data analysis?
What does BISG stand for, and what does BISG mean for Fair Lending Compliance?
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?
We qualify loan applicants based on gross income. Our credit officer says that tax free income from SSI or VA Disability is the gross income and shouldn't be grossed up. I say the income is net and should be. Who's right? If we don't gross tax SSI up, are we discriminating?
We want to start charging our customers for credit reports and flood determinations. Is it ok to only charge customers that we actually close the loan with or would this be discriminatory? We don't want to charge the credit report fee at application. We would rather wait until the loan is closed before the fee is imposed on the customer, therefore if a denial is made, the denied customers would not have the fee imposed on them.
What website information are we required to keep? Are we required to store our old website pages on the server?
Our legal department just notified us that the Equal Housing Lender poster will need to be updated because the FDIC is making changes. Can you tell me where I can get copies of the updated poster? Is it available in both hard copy and PDF format?
I am brand new to compliance at a small national bank that does not do HMDA reporting. Do we still have to collect the information (gray areas of the residential loan application) as required by 12 CFR 27?
I just ordered Equal Housing Lender posters in October 2007 and another person in the bank ordered them since then. I got mine from the Comptroller of the Currency and the others came from the FDIC. They are exactly the same except for the address for processing under the Federal Fair Housing Act. The posters I received have an address for the Comptroller of the Currency and the other posters ordered have an address for the FDIC. Which is correct or does it matter?