When an individual purchases rental property, such as a duplex, to fix up and sell, is this a HMDA reportable loan?
Currently our Rate and APR for the HELOC program are the same on the published rate sheet. This is a variable rate loan product, shouldn't the APR be different taking into consideration the floor and cap on the rate for this type of loan?
Are Appraisal Review fees and environmental report fees considered prepaid finance charges?
HMDA exempts from reporting any loans that are for temporary financing. Temporary financing is not defined by the regulation; however, one definition used by banks is that a temporary loan is a loan with a maturity of 2 years or less that has a balloon payment and is to be repaid from other than earned income. Does this hold true for home improvement loans? What if a home improvement loan is amortized over 6 months or 12 months? Please advise me on whether or not short term home improvement loans are reportable on HMDA.
We are in the process of developing a more comprehensive IT/Information Security policy for our growing institution. What recommendations can you make regarding content that will insure compliance with regulators? Are you aware of any sample policies that meet regulatory criteria that we can refer to for guidance? We are most interested in sucessful ways of incorporating GLBA requirements.