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#448806 - 10/28/05 02:27 PM FDIC - Compliance Exam
Anonymous
Unregistered

Our exam begins soon and on the list of type of loan files that they would like to review they have listed multiple advance consumer construction loans. Can anyone help me what they will be looking at on these types of loans beside the normal disclosure issues?

Thanks

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Lending Compliance
#448807 - 10/28/05 02:48 PM Re: FDIC - Compliance Exam
Dan Persfull Offline
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Dan Persfull
Joined: Aug 2002
Posts: 47,517
Bloomington, IN
Did you calculate the APR correctly using the options in Appendix D, are inspection fees (if any) properly disclosed as finance charges, if you may do the end financing was the RESPA disclosures given, etc.
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The opinions expressed are mine and they are not to be taken as legal advice.

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#448808 - 10/28/05 09:00 PM Re: FDIC - Compliance Exam
Rangers Fan Offline
Gold Star
Rangers Fan
Joined: Dec 2001
Posts: 345
It may also depend on which state you are in. In Oklahoma, the FDIC only looks at HELOCS (but not advanceable consumer construction loans)since we are covered by the UCCC and the State Banking Department will look at that side when they come in (for state, non-member banks). Do have fun and good luck!!

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#448809 - 11/03/05 11:37 PM Re: FDIC - Compliance Exam
SavannahOne Offline
Diamond Poster
Joined: Sep 2005
Posts: 1,163
Georgia
They may also be curious whether there are "open-end" loans hidden within your multiple advance portfolio.

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