03/24/2019
If a business customer has a privately owned ATM in their business, are they considered an MSB?
03/17/2019
The maximum amount of flood insurance that can be purchased on a condo is 80% of the replacement cost of the building or the total number of units in the condo building times $250,000, whichever is less.
What if there is no documented Replacement cost on the building, should we use the appraisal value as the basis of our calculation?
03/17/2019
Our borrower is an individual. The purpose of the loan is refinancing a first lien with another lender. The property owner is Trust. Is this acceptable and do you have any recommendations for dealing with this scenario?
03/17/2019
We issued a Loan Estimate for a bridge loan to purchase a home to be secured with the purchased property and the applicant's current residence. Due to timing circumstances with the applicant and the sellers, the applicant now wants to expedite the purchase by using an investment account and use the TRID loan to get reimbursed. Can I use the same application and re-disclose the LE as a refinance or home equity purpose?
03/10/2019
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?
03/10/2019
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?
03/10/2019
Can you add force placed insurance to a non-accrual loan that is well collateralized? State laws and the contract allow it for it.
03/10/2019
We recently switched credit bureau vendors. This vendor automatically includes the credit score disclosure exception notice with the credit report. We in turn provide this disclosures to those who apply for consumer credit. There are times when a lender will use a consumer report for a business purpose loan. If we provide the credit score disclosure exception notice on a business purpose transaction/application are we asking for trouble with examiners? Could we be subject to fines?
03/03/2019
We are a commercial bank in New York. Do we need to report interest that is paid on our real estate escrow accounts to the IRS?
03/03/2019
A question has come up in regard to public comments left on the bank's Facebook page. Would Facebook comments that relate to the bank's performance in helping meet community credit needs rise to the level of placing these in the bank's Public File?
