Skip to content
BOL Conferences
Thread Options
#2211467 - 04/17/19 08:18 PM Reg B - Action Taken
clinds Offline
Member
Joined: Sep 2017
Posts: 66
In the following scenario, what would be the Reg B action taken and what notice, if any, would be provided to the applicants?

The application is for a construction loan. A completed application was received in March. Conditional approval was documented and communicated in April. The only condition not met at the end of May was to have 10% cash reserves in a bank account. The loan officer and applicants had ongoing communication in June and July; however, the applicants did not agree with certain language that would be in the Note and did not agree with the bank’s requirement for a 10% cash reserve. The bank would not make concessions on either of those items. The applicants stopped communicating with the bank at the end of July.

Return to Top
Lending Compliance
#2211480 - 04/17/19 09:47 PM Re: Reg B - Action Taken clinds
rlcarey Online
10K Club
rlcarey
Joined: Jul 2001
Posts: 83,227
Galveston, TX
Conditional approval was documented and communicated in April.

With what expiration date?
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

Return to Top
#2211495 - 04/18/19 01:26 PM Re: Reg B - Action Taken clinds
clinds Offline
Member
Joined: Sep 2017
Posts: 66
The conditional approval was documented from the loan committee and communicated to the lender. The lender then communicated verbally to the borrower the requirement for 10% cash reserves. There is no documentation on an expiration date but the assumption is the 10% cash reserves had to be in the bank account at closing.

Return to Top

Moderator:  Andy_Z