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#1649685 - 01/11/12 09:06 PM Green Loan Program
husker14 Offline
Member
Joined: Aug 2005
Posts: 50
Management has directed we support a loan program with one of our area developers. The loan purpose is for energy improvements with 10 year terms, fixed rate, secured by UCCs on the improvement (say solar windows, 10,000-50,000 only, the developer to collect the applications and send to us and the developer is providing a 10% reserve for each deal. This program was originally offered by the State of California but they have dicontinued it for now. I know we have HMDA, CIP, rescission, adverse action issues. What about early disclosures? I have talked to two examiners and got two different answers???? Anything else???

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Lending Compliance
#1649743 - 01/11/12 10:11 PM Re: Green Loan Program husker14
rlcarey Offline
10K Club
rlcarey
Joined: Jul 2001
Posts: 79,935
Galveston, TX
What about just making them unsecured? What do you plan to do when they default with your UCC filing, come and rip the windows out of the house? Beside a UCC secured loan is not dwelling secured, so why early disclosure or rescission unless dictated by State law?
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