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#1701647 - 05/21/12 04:42 PM RESPA & Commercial Loan Letters of Intent
ccrofford Offline
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Joined: Aug 2011
Posts: 48
Is there a final rule anywhere stating that banks have to have a signed joint of intent on commercial loan applications? Or are commercial and business loans still currently exempt from all RESPA requirements?

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Lending Compliance
#1701718 - 05/21/12 06:31 PM Re: RESPA & Commercial Loan Letters of Intent ccrofford
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,293
Joint intent is a Regulation B requirement and applies to all types of loan applications.
_________________________
Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
www.kaybeescomplianceinsights.com

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#1701732 - 05/21/12 06:53 PM Re: RESPA & Commercial Loan Letters of Intent ccrofford
ccrofford Offline
Junior Member
Joined: Aug 2011
Posts: 48
Thats what I found after I posted this...Joint Intent does not apply to commercial loans under RESPA, but it is required to be verified under Reg B-ECOA. Thank you!!

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#1701735 - 05/21/12 06:56 PM Re: RESPA & Commercial Loan Letters of Intent ccrofford
RR Joker Offline
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RR Joker
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Posts: 20,654
The Swamp
I think you are confusing Intent to Proceed with Intent to apply jointly.

Two entirely different subjects.

You have no requirements under RESPA on true commercial deals.
_________________________
My opinion only. Not legal advice.

Say you'll haunt me - Stone Sour

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#1701876 - 05/21/12 11:22 PM Re: RESPA & Commercial Loan Letters of Intent ccrofford
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,293
Right...RESPA has nothing to do with joint intent. Joint intent is a Regulation B requirement and applies to all loan types: consumer, commercial, everything.

RESPA does require intent to proceed, but does not apply to commercial loans
_________________________
Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
www.kaybeescomplianceinsights.com

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