Can a Financial Institution send out a debit card to an existing customer, even if the current card is not expired? The FI would be sending the new card as a marketing tool, so to someone who hasn't used the card in quite some time. What about if it is a credit card? Same question, but is the answer the same?
My question is that our compliance department is asking operations to gather GMI on all unsecured consumer loans that are currently on our books. The purpose is to run comparisons for fair lending. I have researched this and find that it is not allowable under Reg B, however the argument is that these are already our loans and we are not asking the borrower for it up front to make a lending decision. I would appreciate your opinion.
Are mortgage lenders required to issue a credit decision (conditional approval or Pre-approval or notice of incompleteness or denial) on purchases and a commitment letter on refi's within 30 days of application? We have a purchase of new construction file that sat for 4 months while construction finished with no credit decision.
(Under ECOA) After we have a credit-only approval for an application, how long can the application remain active in our pipeline? For example, if we submit a credit-only file to an underwriter (without a property) and the file is conditionally approved (based on credit qualification only), and the applicant is looking for a home or waiting for a new construction to be finished, how long can we hold that app in our pipeline before getting scrutinized by an examiner (we are under the FRB)?
I’ve seen a range from 45 to 90 days – but obviously, we want as big of a window as possible before we have to action the loan … especially if the borrower is simply waiting for their property to be completed.
Do we have to give an appraisal disclosure to a home builder for each dwelling that is being built or can we use a master disclosure to cover all dwellings being built in the housing development?
The CFPB recently posted an update to what the difference is between a preapproval and a prequalification.
Has there been a change in regulation that minimizes Preapprovals?
We have a customer that has horrible credit, but owns acreage and real estate. Her only income is $500 a month. She wants to borrow money using her property as collateral. Her father, 86 years of age, will be on the deed and loan with her. He has income sufficient to support the loan but does not live with her. Can his income be included in the debt to income since he will not be living in the home?
Where can I find the regulation that states if a lender denies a loan application, the loan applicant must wait 30 days before reapplying?
I have a question regarding joint intent, and documentation of such. If you have two unmarried borrowers - separate credit reports - is it required to have separate 1003s (applications)? If not, does joint intent apply according to the application or credit report (assuming they are run on different days). If they are required to have separate 1003s, does joint intent still apply and need to be documented?
What is required on a loan application?