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#2148829 - 10/05/17 04:34 PM Loan Term on non-originated files
Banker K, CRCM Offline
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Joined: Jan 2010
Posts: 293
Oklahoma
Can we report "NA" on non-originated loans for the Loan Term field in 4(a)(25)?

The sole example they give in OI-5 is for "reverse mortgages". Not sure if that example was exclusive or not.

In some instances, we have a non-originated file in which the customer and officer did NOT decide on the term of the loan before it was shut down.
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#2148842 - 10/05/17 04:49 PM Re: Loan Term on non-originated files Banker K, CRCM
David Dickinson Offline
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David Dickinson
Joined: Nov 2000
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Central City, NE
…scheduled number of months after which the legal obligation will mature or terminate or would have matured or terminated. [§1003.4(a)(25)]

Specific to reverse mortgages, Comment #5 to this section states:
5. Loan or application without a definite term. For a covered loan or application without a definite term, such as a reverse mortgage, a financial institution complies with § 1003.4(a)(25) by reporting that the requirement is not applicable.
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#2148851 - 10/05/17 05:17 PM Re: Loan Term on non-originated files Banker K, CRCM
Banker K, CRCM Offline
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Joined: Jan 2010
Posts: 293
Oklahoma
Ah thank you again!
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#2160914 - 01/18/18 06:49 PM Re: Loan Term on non-originated files Banker K, CRCM
RVFlyboy Offline
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RVFlyboy
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Soaring over Georgia
What if the applicant didn't complete the requested term on the application form that was submitted by mail and application is being denied because of credit factors? Do we leave blank? Report NA? Something else?
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#2160984 - 01/19/18 12:54 PM Re: Loan Term on non-originated files Banker K, CRCM
Adam Witmer Offline
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Joined: Sep 2010
Posts: 2,658
Great question, Jim. I scrubbed the pre-amble and there isn't a thing addressing this. My initial thought is that NA seems appropriate as there isn't a definite term for those applications:

From the CFPB reference chart:
Enter “NA” for covered loan or application without a definite term, such as a reverse mortgage, Comment 4(a)(25)-5
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All statements are my opinion, not those of my employer, and should not be taken as legal advice.
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