Skip to content
BOL Conferences Top Gun 23
Thread Options
#1707063 - 06/05/12 09:56 PM bankersonline mortgage loan compliance matrix
Lonnie Offline
New Poster
Joined: Jun 2012
Posts: 7
Minnesota
We have been using the excellent http://www.bankersonline.com/tools/ccmatrix_dg.xls tool to quickly review mortgage loan applications for compliance needs. This was last updated 10/27/09. Will it be updated in the future? If so, I have a farm customer applying for a farm purpose loan secured by his Lake Home which is not his primary residence. Does that senario fit anywhere in the matrix? Thank you.
_________________________
Lonnie

Return to Top
Lending Compliance
#1707120 - 06/06/12 11:57 AM Re: bankersonline mortgage loan compliance matrix Lonnie
rlcarey Online
10K Club
rlcarey
Joined: Jul 2001
Posts: 80,378
Galveston, TX
Since that link does not work, what specific tool are you referring too?

It would be a business purpose loan, so the consumer compliance regulations will not apply.
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

Return to Top
#1707505 - 06/06/12 06:28 PM Re: bankersonline mortgage loan compliance matrix Lonnie
Lonnie Offline
New Poster
Joined: Jun 2012
Posts: 7
Minnesota
Sorry, this was a link to a Microsoft Excel File that is apparently still on my computer but not on the web. I tried to attach it to this thread, but was unable. I sent a copy to rlcarey above and to Andy Z, Moderator with request to post it here. Reg Z doesn't apply to business loans, but some regs do: Reg B, FCRA, Reg H - Flood, and Reg C - HMDA.
_________________________
Lonnie

Return to Top
#1707539 - 06/06/12 07:01 PM Re: bankersonline mortgage loan compliance matrix Lonnie
Lonnie Offline
New Poster
Joined: Jun 2012
Posts: 7
Minnesota
Okay, what the matrix does is collect 3 pieces of information, 1. Type of Security, 2. Use of Security, and 3. Use of Loan Proceeds, and from those 3, it trys to tell the user which of 19 different Regs and/or forms or procedures apply. In the column under each of those 3 headings are listed normal things that would apply to that loan application. You highlight all the entrys under Type of Security that apply, highlight all the entrys under Use of Security that apply, highlight all the entrys under Use of Proceeds that apply. Then you find a horizontal line that has all three highlighted and follow it accross to see which of the 19 Regs, forms, or procedures apply. I would gladly email this to the first 10 email addresses that request since it is not possible to attach the Excel file to this thread.
_________________________
Lonnie

Return to Top
#1707579 - 06/06/12 07:35 PM Re: bankersonline mortgage loan compliance matrix Lonnie
Gatorgirl Offline
Member
Joined: Jun 2007
Posts: 55
Florida
I would love a copy! you can email me at bmcquaig@cfl.rr.com

Thanks!

Return to Top
#1707597 - 06/06/12 07:51 PM Re: bankersonline mortgage loan compliance matrix Gatorgirl
Peach Offline
100 Club
Peach
Joined: Sep 2006
Posts: 179
Out West
I would like a copy as well. mclark@yourfsb.com

Thanks in advance

Return to Top
#1707640 - 06/06/12 08:17 PM Re: bankersonline mortgage loan compliance matrix Lonnie
Reads Regs Offline
Diamond Poster
Joined: Nov 2004
Posts: 2,296
_________________________
Opinions expressed are my own and not necessarily those of my employer. They are not legal advice.

Return to Top
#1707652 - 06/06/12 08:26 PM Re: bankersonline mortgage loan compliance matrix Lonnie
Lonnie Offline
New Poster
Joined: Jun 2012
Posts: 7
Minnesota
We use Harland Laser Pro to generate our application and loan documents but we still have a packet of written forms including a 4 page compliance checklist and one of these matrix forms to double check that we have checked each box and completed each field in the software and printed each form. Also these ridiculous timing requirements. It is funny we are not all in jail for trying to help our customers. I think this is a great matrix, but it could be improved a little, like by adding the scenario that I first discussed above to it. Please let me know what you think of it and send me a copy of any improvements. Thanks.
_________________________
Lonnie

Return to Top
#1707665 - 06/06/12 08:31 PM Re: bankersonline mortgage loan compliance matrix Lonnie
Lonnie Offline
New Poster
Joined: Jun 2012
Posts: 7
Minnesota
Not Bad, Reads Regs, but yours only has 10 applicable regulations and it still doesn't answer the question: What regs apply to a farm purpose loan secured by a Lake Home that is not the primary residence. But I like the way you think.
_________________________
Lonnie

Return to Top
#1707671 - 06/06/12 08:34 PM Re: bankersonline mortgage loan compliance matrix Lonnie
Dani York, CRCM Offline
Power Poster
Dani York, CRCM
Joined: Apr 2005
Posts: 3,663
TN
Lonnie, what you describe sounds like the matrix from David Dickinson that Reads provided, but was maybe customized by someone.

If the loan is truly a farm loan (for purposes of running a farm as a business), it is generally exempt from consumer disclosures as a business purpose loan and would not be listed on a consumer compliance matrix.
_________________________
I can't herd the cats anymore, so I just set up the electric fences and let them fry when they stray out of bounds.

Return to Top
#1707716 - 06/06/12 09:27 PM Re: bankersonline mortgage loan compliance matrix Lonnie
Lonnie Offline
New Poster
Joined: Jun 2012
Posts: 7
Minnesota
Am I wrong that the following regs do apply: Reg B, FCRA, Reg H - Flood, and Reg C - HMDA? Out here in farm country the same lenders in our bank handle business, agriculture, home mortgage, and consumer loans. And some of us handle compliance as well and manage the investment portfolio and occasionally wait on customers at the teller counter. For those of us double, tripple, and quadruple duty employees, we need all the help we can get. I think it is nice to have an all inclusive matrix to help us check ourselves to be sure we comply with the applicable regs. Oh, lets not forget Regulation O.
_________________________
Lonnie

Return to Top
#1712633 - 06/20/12 10:36 PM Re: bankersonline mortgage loan compliance matrix Lonnie
Lonnie Offline
New Poster
Joined: Jun 2012
Posts: 7
Minnesota
Okay, I sent a couple more copies of the matrix out today to email requests. Sorry I didnít get back to you quicker. I was out of the bank at a meeting.

The Matrix is an Excel file. The way this thing works if you can say yes to all 3 of the first 3 columns going across in any row, then the laws and regs in that row apply. The first three columns are Type of Security, Use of Security, and Use of Proceeds. There are examples of various answers in those columns.

Again it doesnít seem to answer the question of what compliance laws and regulations apply to a farm purpose loan secured by a Lake Home that is not the primary residence. By the looks of the matrix, it should answer that question as it answers similar questions. The author did a great job, but I really think the author didn't think of this particular scenario.

Send me a copy if you update it. lecsbcmn@frontiernet.net
Lonnie
_________________________
Lonnie

Return to Top
#1712739 - 06/21/12 02:53 PM Re: bankersonline mortgage loan compliance matrix Lonnie
Always In Training Offline
Diamond Poster
Joined: Jul 2006
Posts: 1,115
Where the Green Grass Grows
I use the one Reads Regs linked from David Dickinson. You are right, it doesn't cover every single thing. For instance, it doesn't cover situations when there is mixed use collateral. It also doesn't scratch the surface of my state's rules on homestead. It's a free matrix! Auditors and examiners use it. For those oddball situations - use it as a start, or create your own! There are now more variables than ever when it comes to the minefield of RE lending compliance.

As was stated earlier, loans for ag/farm purpose are considered non-consumer and are thus exempt from Truth in Lending and RESPA. That should help with what you asked.
Last edited by Always In Training; 06/21/12 02:58 PM.
Return to Top
#1712742 - 06/21/12 02:56 PM Re: bankersonline mortgage loan compliance matrix Lonnie
waldensouth Offline
Power Poster
waldensouth
Joined: Nov 2001
Posts: 7,981
FINALLY ABOVE the gnat line
We created our own - used to have it printed out and laminated for each loan officer. Things have been changing so much that we now simply house it on the intranet. Lenders love it.
_________________________
"Once you learn to read, you will be forever free."

- Frederick Douglass




My Opinion Only.

Return to Top
#1713499 - 06/22/12 08:21 PM Re: bankersonline mortgage loan compliance matrix Lonnie
crlittle63 Offline
New Poster
Joined: Dec 2010
Posts: 10
I would love a copy of the matrix!

clittle@firstbaldwin.com
Last edited by crlittle63; 06/22/12 08:22 PM.
Return to Top

Moderator:  Andy_Z