Posted By: KTMiteComply
HMDA Withdrawn - REGB Denied - 04/05/18 12:44 PM
Hey good morning,
I think all my years of training in a small town community bank is clashing with big city training and I'm missing a link in my comprehension. The way our process was in a small bank there was really never a way that you Denied a file for REGB purposes but reported it Withdrawn on the HMDA LAR. So I wanted to give you this scenario and maybe you can explain if this is the case here and give me any additional guidance to understand.
I had stated the file needed to be Denied for BOTH REGB and REGC purposes.
Loan DTI is 78% and Policy states we must be 43%. Our procedures is it must go to UW to make a credit decision. The UW did review the Income portion of the file as a courtesy for the LO but did not fully UW the file. There are numerous tax returns/retirements/paystubs all in the file to be reviewed before this 1/13 stmt below.
Per the LO here is his comment in the file that "triggered" my perception that this file should be Denied:
1/13 - "Emailed Client and advised DTI is high and requesting Income Verification and LIabilities"
I went in and read the copy of the email and it reads like this: "The UW is coming up with "X" amount of Income without this property you are claiming for additional Income. What that means is your DTI is at 80%...are you coming up with that Income and Liabilities for us to review?"
1/16 - Borrower emails and states: As we review the LE we are reading we will need X amount to close and we do not have X amount to close. Please Withdraw this loan.
So is this just a Withdrawal all the way around the block for REGB & REGC since it never formally went to UW for a full UW review?
Is this a Denial for REGB purposes since it appears a Negative Credit Decision was communicated about DTI requirements?
Is this a Denial for REGB and a Withdrawal for REGC?
Thanks for any input and training you guys can give me to learn,
Karen
I think all my years of training in a small town community bank is clashing with big city training and I'm missing a link in my comprehension. The way our process was in a small bank there was really never a way that you Denied a file for REGB purposes but reported it Withdrawn on the HMDA LAR. So I wanted to give you this scenario and maybe you can explain if this is the case here and give me any additional guidance to understand.
I had stated the file needed to be Denied for BOTH REGB and REGC purposes.
Loan DTI is 78% and Policy states we must be 43%. Our procedures is it must go to UW to make a credit decision. The UW did review the Income portion of the file as a courtesy for the LO but did not fully UW the file. There are numerous tax returns/retirements/paystubs all in the file to be reviewed before this 1/13 stmt below.
Per the LO here is his comment in the file that "triggered" my perception that this file should be Denied:
1/13 - "Emailed Client and advised DTI is high and requesting Income Verification and LIabilities"
I went in and read the copy of the email and it reads like this: "The UW is coming up with "X" amount of Income without this property you are claiming for additional Income. What that means is your DTI is at 80%...are you coming up with that Income and Liabilities for us to review?"
1/16 - Borrower emails and states: As we review the LE we are reading we will need X amount to close and we do not have X amount to close. Please Withdraw this loan.
So is this just a Withdrawal all the way around the block for REGB & REGC since it never formally went to UW for a full UW review?
Is this a Denial for REGB purposes since it appears a Negative Credit Decision was communicated about DTI requirements?
Is this a Denial for REGB and a Withdrawal for REGC?
Thanks for any input and training you guys can give me to learn,
Karen