What’s the most severe penalty for a military lending violation you’ve seen?
What action steps are needed when we find a severe or frequent violation?
Can we report a past due loan to the credit bureau when SCRA protections apply?
Why is a permissible purpose needed to get someone’s credit report?
We found an HPML in our audit. There is no escrow set up. What can we do?
Can we collect property taxes during construction based on the completed value of the home?
How do we know when a cushion is allowed?
We often have lobby posters advertising products, services, benefits like trips on a discounted price and others things on display so staff can answer questions on these and to promote these items. Do they require the general FDIC advertising statement>
If we price HELOCs based on the applicant's credit score and loan to value ratio, so some borrowers get a lower rate than other borrowers, can we disclose the lower rate in our advertisement, or do we need to disclose both rates? Do we also need to specify the criteria for receiving the lower rate?
There are competing thoughts on the appropriate way to treat an application when the Loan Estimate is not provided by the 3rd business day following the applicant's submission of the six pieces of information.
Theory 1 - Cancel the existing application and restart the application process. This may be due to some issues with selling the loan on the secondary market.
Theory 2 - Show it cas a "self-identified" issue on the file and continue with the file as is. As long as it is not a pattern in practice and is just a one-off from the established controls, there should be no ramifications.
Please help in identified whether #1 or #2 (or may be a 3rd option we aren't thinking of) would be the most appropriate.