Most Popular Compliance Content
ROR Needed When Changing a Rate on Note?
04/28/2008
Do we need a right of rescission disclosure when we are just changing the rate on the note? We do have first on the property. The purpose of the loan was to reimburse the borrower for home construction costs paid out of pocket.
SMB Loan Portfolios
04/21/2008
What steps can banks take to protect against losses in its small business loan portfolio?
Deposit Account Required for Loan Approval?
04/21/2008
If an applicant meets our lending guidelines (credit, debt ratio, etc.) can we as the lender require the applicant to establish a depository relationship with our bank before we approve the loan request (for a mortgage and/or consumer loan)?
Collecting GMI on Loans Not Reported on HMDA LAR
04/21/2008
We have chosen to not report HELOCs on the HMDA LAR, but we do collect GMI on all home loan applications. I cannot find in Reg C that we are prohibited from collecting the GMI data for loans not reported on the HMDA LAR. Is collecting this data on loan applicants against any regulation and if so, could you please site the regulation?
Flood Insurance Coverage Conundrum
04/21/2008
We have financed the construction of a six story condominium building that is located in a flood zone. Our borrower is a commercial entity and for our purpose, the project is a commercial development. Our borrower has obtained $250,000 of flood insurance coverage, however, we are requiring $500,000 which is the maximum available for commercial property through FEMA. The borrower's insurance company has been unable to increase the policy. The insurance company states that the building is residential in nature since the end result will be a condo building. The insurance agent has tried to convince the insurance company that it is really a commercial property and has been unsuccessful in this argument. Do you have any suggestions or solutions for our insurance conundrum?