How much "teeth" does UDAAP really have to penalize a bank?
Disparate treatment is still illegal but didn't the Supreme Court overrule disparate impact cases?
As to a loans HOEPA status, are second homes and vacation homes considered not applicable for HOEPA which would make the status code 3 on the HMDA LAR report?
Our commercial applicant submitted an application and we issued a (expression of interest) EOI / Term sheet. The loan officer is in communication with them and is asking for items we require to underwrite the loan. It is taking more than 60 days to receive all the items. They are coming in piece by piece. When are we required to send a notice of incompleteness? I was understanding that an NOIA would not be required since the application is still not complete and we are working with the applicant, but others are saying it should be sent now.
What do we report for property value and loan to value if two properties secure the loan, but one was taken in an abundance of caution (AOC) and treated as AOC for the appraisal requirements?