Vendor Guru Q&A - Lending

Latest Lending - Advertising Topics

Commercial loans are fair lending issues

09/13/2020

How does fair lending impact commercial loans, which is not “consumer protection” controlled?

Equal Housing Lender logo for Advertising

09/06/2020

We don't make owner occupied mortgages, but do make business purpose loans for rental properties. Do we need to continue using the Equal Housing Lender logo in advertising?

Are LPOs the answer?

09/06/2020

Will Loan Production Offices help in fair lending if we decide to close branches?

Fair lending is more than mortgages

08/30/2020

The CFPB hasn’t been active in fair lending other than mortgages, correct, does this present any challenges?

CRA assessment areas changing

08/23/2020

How might national banks assessment areas be impacted by the new CRA rules?

HMDA data must be scrubbed

08/16/2020

What was the HMDA data problem from 2019?

Can I copy an ID?

07/26/2020

Ever since CIP we started keeping copies of IDs in our files. Is this OK?

We had the 6 points of information for an application but lost track of the request and took too long to deny it as we were awaiting additional income information from the applicant. What can we do now?

Credit Card Promotion-Waive Annual Fee

07/05/2020

The bank is considering a credit card promotion for a period of 90 days that will waive the annual fee for the life of the credit card. A customer must apply for the credit card during this time frame to be eligible. It will not be advertised externally. Must the credit card application be altered or can we leave the annual fee on the app in case other customers take the application with them? What other compliance requirements exist for this type of promotion?

AAN? We don’t make those loans.

06/21/2020

During the PPP loan programs we had many requests, but we were not participating? These are commercial requests and would be subject to Reg B. Were adverse action notices required?

Are all deposits income for a loan?

12/25/2022

If the borrower receives funds as the rep payee for his disabled brothers, can that money be counted as income for the borrower when completing underwriting?

Military Lending Rules

12/25/2022

Hasn’t military lending been quiet this year?

What's our decision for HMDA?

12/18/2022

We have a purchase mortgage application that was approved with all underwriting conditions met. In review of the title run it was discovered the seller could not convey a clear title to the property. We did send the borrower a Notice of Action for Incomplete Application giving 10 days for clear title to be received. For HMDA purposes would the Action Taken be Approved Not Accepted or Denial?

Exception commenting

12/18/2022

What is an exception comment?

Modifying a Construction Loan

12/18/2022

We have an existing construction loan that we would like to increase. Will this have to follow TRID rules or can we do a modification to increase the loan amount, charge a 1% loan fee on the new proceeds, add filing fees, title fees and any other fees that may be associated with the modification?

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