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#1769693 - 12/21/12 03:03 PM Banker's Tools RE-Consumer Purpose
Combustible Offline
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I'm confused--in your Banker's Tools checklist for R/E as collateral for consumer purpose loan, under application, the first item "Application" states: "Application without monitoring info"? I think I must be missing something--be nice!

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Lending Compliance
#1769695 - 12/21/12 03:08 PM Re: Banker's Tools RE-Consumer Purpose Combustible
Combustible Offline
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I should also have noted this is under the commercial lending topic-

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#1769696 - 12/21/12 03:09 PM Re: Banker's Tools RE-Consumer Purpose Combustible
raitchjay Online
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OK
Which checklist? I'm looking at Banker's Tools and there are tons of checklists. smile
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#1769697 - 12/21/12 03:09 PM Re: Banker's Tools RE-Consumer Purpose Combustible
raitchjay Online
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Joined: Oct 2009
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OK
Oh.
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#1769699 - 12/21/12 03:13 PM Re: Banker's Tools RE-Consumer Purpose Combustible
raitchjay Online
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Joined: Oct 2009
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OK
If i'm looking at the same one as you, that seems a little vague to me. "Real estate" may or may not include a dwelling, and banks may or may not be HMDA reporters, so blanket statements of "need GFE" or "need application without monitoring" don't really work, IMHO.
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#1769741 - 12/21/12 03:57 PM Re: Banker's Tools RE-Consumer Purpose Combustible
Combustible Offline
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Of course, thanks for reminding me that RE may not include a dwelling. Sometimes my past experience as a RE agent and past experience as a lender get in the way of my now position in compliance. Most of the time it's helpful, but sometimes what I learned before compliance wasn't always lawful. I'm trying to update our Commercial Lending program, and in our latest commercial exam we ran a cross a problem with a HMDA reporting bank not collecting GMI on business loans to individuals purchasing or refinancing 1-4 family rental properties. I learned a lot in the review, and so have the commercial lenders. I held off from asking BOL questions, because I worked with the help of a very experienced compliance person who pointed out to me the need for GMI collection on something other than the HMDA entry log. So now, that I've gotten your attention, I'll ask for your experience also concerning this issue. Please let me know if I need to clarify--I usually do! Thanks

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