2017 HMDA Rules: Long Term Loans-Purchase?
02/11/2018
For 2017 HMDA rules, are long term loans secured by bare ground with intentions to build in 24 months reportable and are they reported as purchase loans?
David A. Dickinson
Bio:
David's banking career began as a field examiner for the FDIC in 1990. He later became a Loan Officer for a small bank. In 1993, he established Banker's Compliance Consulting. Along with his amazingly talented Team, he has written numerous compliance articles for prestigious banking publications and has developed compliance seminars that Banker's Compliance Consulting produces.
He is an expert in compliance regulations. He is also a motivational speaker and innovative educator. His quick wit and sense of humor transforms the usually tiring topic of compliance into an enjoyable educational experience. David is on the faculty of the Center for Financial Training, the American Bankers Association National Compliance Schools and is a frequent speaker at the ABA's Regulatory Compliance Conference. David is also a trainer for hundreds of webinars, is a Certified Regulatory Compliance Manager (CRCM) and has been a BankersOnline Guru for many years. The American Bankers Association honored David with their Distinguished Service Award in 2016.
David and his wife Karen have 3 adult children (none of whom live at home!) & 3 cats (which Dave is allergic to). They live on a lake in Nebraska and when possible, Dave can be found fishing or in the water. David plays the guitar & piano and enjoys singing with Karen. Together they lead worship at their church.
See all Upcoming and On-Demand training presented by David.
He is an expert in compliance regulations. He is also a motivational speaker and innovative educator. His quick wit and sense of humor transforms the usually tiring topic of compliance into an enjoyable educational experience. David is on the faculty of the Center for Financial Training, the American Bankers Association National Compliance Schools and is a frequent speaker at the ABA's Regulatory Compliance Conference. David is also a trainer for hundreds of webinars, is a Certified Regulatory Compliance Manager (CRCM) and has been a BankersOnline Guru for many years. The American Bankers Association honored David with their Distinguished Service Award in 2016.
David and his wife Karen have 3 adult children (none of whom live at home!) & 3 cats (which Dave is allergic to). They live on a lake in Nebraska and when possible, Dave can be found fishing or in the water. David plays the guitar & piano and enjoys singing with Karen. Together they lead worship at their church.
See all Upcoming and On-Demand training presented by David.
Areas of Expertise:
Audit Services
Compliance Audits
Compliance Consulting
Compliance Review
Compliance Seminars
Lending
Lending & Operations Compliance Matrices
Risk Assessment
Organization Health / Culture Consulting & Training
Training the Trainer Materials
Training Videos
Questions Answered
Combine 2 Different Disclosures Into 1 Sign?
01/28/2018
We want to redo our interior signage, including all the disclosures. Can I combine two different disclosures into one sign?
Pay Ahead On Mortgage-Accrued Interest>Payment
01/21/2018
If a customer chooses to pay ahead on their mortgage loan by several months, causing the accrued interest to be greater than their payment, it is okay for an employee to reverse funds originally applied to principle and apply to accrued interest? This is being done without consent by the customer.
Max Penalty Bank Can Charge on COD
01/14/2018
What is the maximum penalty that a bank can charge on a certificate of deposit?
Requirement to Backdate Loan Payments-Reg Z
01/14/2018
I am a little confused as to the requirement to backdate loan payments that are accepted over the counter and performed via online banking and telephone banking after our 3:00 cutoff time and what type of payments need to be backdated after that cutoff.
Rate Spread HMDA/Reg C: Apply to Construction?
01/14/2018
Does the rate spread under HMDA Reg C apply to construction loans for residential 1-4 family?
Adverse Action on Existing Credit
12/03/2017
Can you give some examples of when we would need to provide a notice of adverse action on an existing credit?
Flood determination on lot loan when home planned?
11/26/2017
We are doing a loan on a residential lot where the customer is going to build a 1-4 family dwelling in the neat future (2-3 years). Is a Flood Determination required?
Customer Contact on Incomplete Applications
11/26/2017
If a lender has a TBD application, are they required to document constant contact with the applicant at least every 30 days?
HMDA Rules-Threshold for Open-End Lines of Credit
11/12/2017
Assuming a Financial Institution meets the 500 threshold for Open-End Lines of Credit, if the institution makes a large open-end line of credit to a builder for the purpose of constructing both spec and pre-sold homes, is the loan HMDA reportable under the new HMDA rules? For purposes of this question, assume the transaction is documented by a master line of $15,000,000 with sub-notes under the master line for each property being constructed. If the Financial Institution does not meet the threshold test, I assume the transaction would not be HMDA reportable. Do you concur?