Intent to Proceed on Commercial Purpose Loans?
06/09/2019
Are we required to have an intent to proceed on commercial purpose loans?
06/09/2019
Are we required to have an intent to proceed on commercial purpose loans?
06/09/2019
Per Reg CC, a banking day is defined as any business day (up to the bank's cut-off hours) when your institution is open for substantially all of its banking activities. Reg CC measures availability of funds in business days. Are we, the bank, allowed any time from open of business to 3:00 pm (our cut off time) to release a hold? Our disclosure goes over the terms Business Day and Banking Day. But under the delay we use Business Day. So should the funds be available the start of business day the hold is removed?
05/19/2019
I'm trying to determine if this commercial loan is HMDA reportable. The borrower is purchasing 295 acres. This mostly vacant land is used primarily for hunting however, there are two dwellings on the property. My question is, can this property be considered primarily agricultural? Referring to Reg. Z guidance on what is considered agricultural, fishing would fit this category but there is no mention of hunting. I wanted to get other opinions as we are leaning towards this being reportable.
05/19/2019
Does Regulation E require you to send dispute resolution letter with all information regarding the transaction, or can we send a generic letter? "Your claim is denied ,"or "your dispute is valid" with no information regarding the date and amount of the transaction? I was always under the impression you had to provide that information in a closure letter.
03/24/2019
I have a closed-end transaction secured by a principal dwelling which is being refinanced to another closed-end product (no new money). The original transaction provided a right of rescission. Please confirm that the refinance loan is not rescindable since it is with the same lender and no new money is being funded. I can't find a cite for this.
03/10/2019
We recently switched credit bureau vendors. This vendor automatically includes the credit score disclosure exception notice with the credit report. We in turn provide this disclosures to those who apply for consumer credit. There are times when a lender will use a consumer report for a business purpose loan. If we provide the credit score disclosure exception notice on a business purpose transaction/application are we asking for trouble with examiners? Could we be subject to fines?
03/03/2019
Is a loan to purchase a shed, HMDA reportable as home improvement? Does the shed have to be on a permanent foundation to qualify as a home improvement?
03/03/2019
I have questions that bother me when I dealing with a commercial real estate transaction where a residential property is taken as collateral. When does the Notice of Right to Receive a copy of an Appraisal apply? I have seen many different concepts in the internet regarding to dwelling: - A 1-4 residential property which is the borrower or guarantor's principal residence; - Any 1-4 residential property which is the borrower's principal residence, and it is going to be refinanced; or - Any 1-4 residential property taken as collateral in the commercial real estate transaction. I would like somebody clarify which is in compliance. I am in Florida if that matters.
03/03/2019
Under current HMDA definition is a mobile home that is attached to real estate considered a 1-to-4 family dwelling or is it manufactured housing? In my opinion a mobile home affixed to real estate is more similar to housing manufactured off site and delivered/affixed to the land than a home that was traditionally stick built on-site. However, a mobile home does not meet the technical HUD definition of manufactured housing either.
02/24/2019
I have a question about the use of the Equal Housing Lender logo. Does it need to be included in a mortgage company email signature?