Posted By: E.E.G.B
NYC Rule 67-A (predatory lending) - 01/02/03 03:56 PM
67-A references a compliance worksheet to help lenders determine whether a loan is high cost. The copy of the ordinance I have doesn't include the worksheet or any link to one - anybody seen an official worksheet? We have our own, but I want to be sure to use the official one if necessary. TIA!
Posted By: JMB
Re: NYC Rule 67-A (predatory lending) - 04/16/03 04:08 PM
Thought I would bring this one back to the top. I'd love to have a copy of one of these worksheets - does anyone have one to share?
Posted By: Strout
Re: NYC Rule 67-A (predatory lending) - 04/22/03 04:02 PM
I also have been hunting a compliance worksheet. FYI, we subscribe to VMP statelink and they indicate this worksheet is lender specific and they do not currently have a sample. I am probably going to beg one of our investors for a copy or come up w/ something similar to our Section 32 test and then add the other "stuff" (u/w judgment, benefit to borr, etc.) indicated in the ordinance.
We probably won't do 10 loans all year in NYC but you know how it is, 1 of the 10 can get you in trouble.
Posted By: E.E.G.B
Re: NYC Rule 67-A (predatory lending) - 04/22/03 04:07 PM
Well, at least the ordinance is still being contested so is not yet in effect.... here's hoping it gets overturned and we never have to deal with it!