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#1170236 - 04/24/09 09:15 PM Sub Division Loans
Compliance Audit Offline
100 Club
Joined: Mar 2005
Posts: 200
In an effort to help our builders that have sub division loans, our lending department would like to put a package together for consumers who buy in the subdivision to originate constructions loans at a very low interest rate and make the take out loan mandatory at our bank.

Any compliance issues?

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Lending Compliance
#1170421 - 04/27/09 01:52 PM Re: Sub Division Loans Compliance Audit
CompDat Offline
Platinum Poster
Joined: Dec 2005
Posts: 553
USA
Lots, can you be more specific?

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#1170865 - 04/27/09 08:18 PM Re: Sub Division Loans CompDat
Compliance Audit Offline
100 Club
Joined: Mar 2005
Posts: 200
They would like to offer anyone interested in new construction in the sub division a construction loan at 4% interest with the stipulation that the take out loan is also originated at our bank.

Thanks for your input - I thought there could be some fair lending issues but am not sure what else.

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#1170874 - 04/27/09 08:29 PM Re: Sub Division Loans Compliance Audit
RR Joker Offline
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RR Joker
Joined: Nov 2002
Posts: 20,654
The Swamp
If it's available to anyone and there are no prohibited applicants, then there is not really a FL issue, unless it's implied due to a very high-end neighborhood...but if it's moderately priced, then shouldn't be an issue.

And, since the benefit goes to the customer, it shouldn't be a section 8 issue, either.
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My opinion only. Not legal advice.

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