Thread Options
#2270038 - 05/04/22 05:28 PM Rate Lock Date Missing
Loki1207 Offline
New Poster
Joined: Jul 2021
Posts: 4
I am conducting a review of construction loan Loan Estimates and I noticed that the rate lock box is marked "yes" on some but there isn't a date after "until" which it should have. I've spoken with collogues in Compliance who said that the construction loan rates have not changed in years so even thought there isn't a date, nothing has changed. They said there is a signed rate lock notice in the files. I don't agree with that but I am not all that familiar with construction loans. I suspect that more LE's don't have this date and time on them and some of the loans have even closed already. I always thought the LE should have a date and time of expiration no matter what, is that wrong? Also, what is the cure for this if loans have already closed? I couldn't find anything on BOL so I apologize if there is already something out there about this.

Return to Top
Lending Compliance
#2270063 - 05/04/22 08:25 PM Re: Rate Lock Date Missing Loki1207
John Burnett Offline
10K Club
John Burnett
Joined: Oct 2000
Posts: 39,629
Cape Cod
If the rate lock YES box is checked, there must be a time, time zone, and date to the right of it.

There is no cure for past sins here. Only retraining and other appropriate personnel actions going forward. Rates are trending upward, in case those other compliance colleagues haven't seen the news. If there is a signed rate lock agreement with the consumer in the file, the YES box is checked and the time and date it expires noted. It's a simple YES/NO rule, but apparently some people can't be bothered with it. Find a way to change their attitude.

Perhaps some retooling of the bank's procedural documents is in order.
Last edited by John Burnett; 05/04/22 08:27 PM.
_________________________
John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8

Return to Top
#2270074 - 05/05/22 01:05 PM Re: Rate Lock Date Missing Loki1207
Loki1207 Offline
New Poster
Joined: Jul 2021
Posts: 4
Thank you John for the information. I just found out that we did not have any policy/rate sheet nor anything in our procedures addressing this. I will be making sure it is taken care of.immediately.

Return to Top

Moderator:  Andy_Z