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Richard Insley

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Guru Emeritus - Thank you for lending your expertise to the BankersOnline.com community.


Questions Answered

Policy for the Financing of Boat Docks/Slips

12/12/2021

I am searching for a policy for the financing of boat docks/slips. Senior management is at odds with one another over whether it is prudent to require the real estate adjoining the dock or if the asset itself is marketable. One senior manager argues that the permit is the value in the asset? So we are looking for a sample policy on this, and any insights from those familiar with such loans.

Outsourcing for Compliance Officer Function

10/03/2021

We are a small community bank with $250 million in assets. We have lost our compliance officer again. Unfortunately, we can't justify a full time position for this. Do you know if banks are outsourcing this function and if so, where do I look to find the firms who offer this service?

Advertising Rate Sheet-"Limited Time Offer"

05/09/2021

We are creating a rate sheet to be used by local Realtors. It will provide the current rates for several types of loan products. Under our in-house loan category, Marketing would like to list "Limited Time Offer" as one of the bullet points. I recommended they provide an expiration date. Marketing wants to show that as follows - "Limited Time Offer. May Expire Without Notice." Since UDAAP is governed by perception of the reader what are your thoughts, I am still leaning toward a hard expiration date. What is required, or commonly done?

Increasing Construction Only Loan-Disclosure

04/18/2021

I have a personal construction only loan that we are increasing. How do I disclose the fees that are associated with the increase? Can the bank charge a processing fee? The rate and maturity date are not changing.

Training Requirements for Different Regulations

10/04/2020

Is there a matrix that shows training requirements for the different regulations? I know BSA is an annual event, but I'm looking for guidance on Reg O, Fair Lending, UDAAP, etc. and especially for the board of directors.

Collecting PMI w/o PMI Insurance Company

03/23/2020

If the bank charges PMI and doesn't have a PMI insurance company that it has to pay can the bank truly collect the PMI? For example, if the bank had loans that didn't sell on the secondary market, and the insurance gets cancelled, can the bank still collect for the PMI?

Business Purpose Loan Changed to Consumer?

03/15/2020

Our collateral consisting of 62 acres of farmland, a residence, a hog barn and a cattle barn appraised for $465,000 in 2017. It is owned by an Amish (full-time farm family) borrower. The land and livestock buildings account for $$395,000 of the overall value. The primary residence comprised $70,000. Our first mortgage loan made in 2017 was a business purpose loan. Now these borrowers want to refinance it to add an additional $80,000 remodel. Is this a still a business purpose loan, or will it be a consumer loan? The total loan balance after the new house addition will be $366,000.

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