Does the new appraisal rule under the ECOA apply to Home Builders?
We do a lot of investment (rental) property financing as commercial loans. They are 1st lien, 1-4 family dwellings. We do not have an official commercial application. Trying to determine if we need to send or give the customer the Appraisal Notice, and if so, 3 days from what date since there is no application?
Reg B - appraisals - can we email a copy of the appraisal to the Borrowers as long as it is secured and we get a read receipt for the email? How long after this do we need to wait to close the loan?
We are in the process of underwriting a request for a Participation Bought deal with HSBC Bank for a committed facility. Is this subject to Reg B?
With regards to Reg B/definitions on a credit request or application. If an applicant comes to us and indicates that he would like to apply for credit but would like to apply for credit in the name of a LLC or business entity that is yet to be formed; is that a credit request, do we have a credit request and are we required under Reg B to enter the request for credit?
Beginning 1/18/2014, are we still required to provide the Right to Receive Copy of Appraisal and Notice for Home Loans Not Secured by a First Lien?
We are a small community bank operating in a predominantly rural community. In many instances, we may have multiple mortgages on a dwelling, cross-collateralized across a customer's loan portfolio.
In determining compliance for the CFPB Mortgage Rules, there are several references to first-lien transactions, Reg B Appraisal rules for instance. If our bank is the only secured creditor with multiple security instruments, are all of the mortgages considered the first-lien or is the first-lien the earliest dated mortgage and all subsequent mortgages are considered junior liens?
Problem: You have completed all the audit workpapers and drawn your basic conclusions.