When populating the collateral address for consumer closed-end, real estate secured loans (TRID), is there an industry best standard for WHERE we obtain this address from? I know that it must always include the zip code, and a location (if an address via US Postal Service is not available), but I'm curious if there is an unspoken standard of what document this is best obtained from, such as the counties property record card, the written evaluation provided to us from a certified appraiser, borrower attested to, etc.
Is Letter of Credit to secure a Bond for the purpose of purchasing a residence HMDA reportable?
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?
I have a mortgage that has been approved, commitment signed and returned, all conditions have been met by the borrower. Borrower has now decided to withdraw. How do I code this? It is not a withdrawal, not a decline. Would it be approved not accepted?
Are there possible compliance violations with Regulations B & C and UDAAP if denial reasons are different on the HMDA LAR than what was on the Notice of
Adverse Action? For example: at the time of decline, the denial reason listed on the NOAA was "Other", but when the file was reviewed for HMDA data
validation, the true denial reason should've been a Collateral decline.
Two years ago we granted a new loan and took a first mortgage on a piece of vacant land as collateral. The loan is now going through a renewal. While completing the evaluation, we learned that the borrower; using his own cash, built a home on the property that’s encumbered. The way our mortgage reads, we have interest in ... all existing or subsequently erected or affixed buildings, improvements, and fixtures...
When we complete the valuation report, should the value of the home be included in the report and furthermore, if so, should the report be mailed to the borrower under Regulation B?
How does HMDA define a "complete" and "incomplete" loan application?
Exceptions that compliance officers monitor?
For 2017 HMDA rules, are long term loans secured by bare ground with intentions to build in 24 months reportable and are they reported as purchase loans?
I attended a seminar last week and I discovered that our bank, which I thought was approving and selling loans, was actually acting as a broker. Upon speaking to the primary loan officer for these loans I found out that we do not do any of the underwriting for these loans, nor do we make the credit decision. The purchaser is putting these loans on their LAR (as they should), but so have we. I have been working here nearly a year now and just found that information out and I am upset with myself for not knowing this information before now. I looked at our LAR from last year and see that nearly half of the loans on the LAR should not have been reported as they were these brokered loans. It is the same story as far back as 2014. Do we
need to go back and re-submit the LAR(s) or can we proceed as normal? Are we looking at penalties? I am really shocked at this news. After several exams and outside audits, this was never discovered until now. I would really appreciate any tips you can offer.