bankersonline mortgage loan compliance matrix

We have been using the excellent http://www.bankersonline.com/tools/ccmatrix_dg.xls tool to quickly review mortgage loan applications for compliance needs. This was last updated 10/27/09. Will it be updated in the future? If so, I have a farm customer applying for a farm purpose loan secured by his Lake Home which is not his primary residence. Does that senario fit anywhere in the matrix? Thank you.

Since that link does not work, what specific tool are you referring too?

It would be a business purpose loan, so the consumer compliance regulations will not apply.

Sorry, this was a link to a Microsoft Excel File that is apparently still on my computer but not on the web. I tried to attach it to this thread, but was unable. I sent a copy to rlcarey above and to Andy Z, Moderator with request to post it here. Reg Z doesn't apply to business loans, but some regs do: Reg B, FCRA, Reg H - Flood, and Reg C - HMDA.

Okay, what the matrix does is collect 3 pieces of information, 1. Type of Security, 2. Use of Security, and 3. Use of Loan Proceeds, and from those 3, it trys to tell the user which of 19 different Regs and/or forms or procedures apply. In the column under each of those 3 headings are listed normal things that would apply to that loan application. You highlight all the entrys under Type of Security that apply, highlight all the entrys under Use of Security that apply, highlight all the entrys under Use of Proceeds that apply. Then you find a horizontal line that has all three highlighted and follow it accross to see which of the 19 Regs, forms, or procedures apply. I would gladly email this to the first 10 email addresses that request since it is not possible to attach the Excel file to this thread.

I would love a copy! you can email me at bmcquaig@cfl.rr.com

Thanks!

I would like a copy as well. mclark@yourfsb.com

Thanks in advance

Were you looking for something like this? http://www.bankerscompliance.com/assets/files/documentation/RE%20Matrix%208.0.pdf

We use Harland Laser Pro to generate our application and loan documents but we still have a packet of written forms including a 4 page compliance checklist and one of these matrix forms to double check that we have checked each box and completed each field in the software and printed each form. Also these ridiculous timing requirements. It is funny we are not all in jail for trying to help our customers. I think this is a great matrix, but it could be improved a little, like by adding the scenario that I first discussed above to it. Please let me know what you think of it and send me a copy of any improvements. Thanks.

Not Bad, Reads Regs, but yours only has 10 applicable regulations and it still doesn't answer the question: What regs apply to a farm purpose loan secured by a Lake Home that is not the primary residence. But I like the way you think.

Lonnie, what you describe sounds like the matrix from David Dickinson that Reads provided, but was maybe customized by someone.

If the loan is truly a farm loan (for purposes of running a farm as a business), it is generally exempt from consumer disclosures as a business purpose loan and would not be listed on a consumer compliance matrix.

Am I wrong that the following regs do apply: Reg B, FCRA, Reg H - Flood, and Reg C - HMDA? Out here in farm country the same lenders in our bank handle business, agriculture, home mortgage, and consumer loans. And some of us handle compliance as well and manage the investment portfolio and occasionally wait on customers at the teller counter. For those of us double, tripple, and quadruple duty employees, we need all the help we can get. I think it is nice to have an all inclusive matrix to help us check ourselves to be sure we comply with the applicable regs. Oh, lets not forget Regulation O.

Okay, I sent a couple more copies of the matrix out today to email requests. Sorry I didn’t get back to you quicker. I was out of the bank at a meeting.

The Matrix is an Excel file. The way this thing works if you can say yes to all 3 of the first 3 columns going across in any row, then the laws and regs in that row apply. The first three columns are Type of Security, Use of Security, and Use of Proceeds. There are examples of various answers in those columns.

Again it doesn’t seem to answer the question of what compliance laws and regulations apply to a farm purpose loan secured by a Lake Home that is not the primary residence. By the looks of the matrix, it should answer that question as it answers similar questions. The author did a great job, but I really think the author didn't think of this particular scenario.

Send me a copy if you update it. lecsbcmn@frontiernet.net
Lonnie

I use the one Reads Regs linked from David Dickinson. You are right, it doesn't cover every single thing. For instance, it doesn't cover situations when there is mixed use collateral. It also doesn't scratch the surface of my state's rules on homestead. It's a free matrix! Auditors and examiners use it. For those oddball situations - use it as a start, or create your own! There are now more variables than ever when it comes to the minefield of RE lending compliance.

As was stated earlier, loans for ag/farm purpose are considered non-consumer and are thus exempt from Truth in Lending and RESPA. That should help with what you asked.

We created our own - used to have it printed out and laminated for each loan officer. Things have been changing so much that we now simply house it on the intranet. Lenders love it.

I would love a copy of the matrix!

clittle@firstbaldwin.com