11/17/2019
We have an online loan application that our members complete. It does not have a signature on it. We use that to pull credit, make the loan and the
members come in and sign loan documents. My question is do I need them to complete a loan application in person with a signature or is the on-line
application sufficient?
11/03/2019
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.
02/03/2019
Concerning a counter offer on a consumer loan. In this case not mortgage related. To my understanding a counter offer applies when you want to change a term from the original request in order to position the borrower to grant approval. IE reduce loan amount, extend duration of term. Can a counter be used to request a co-signer /endorser to be placed on the loan.
With a comment that states this loan would be granted as long as the added co-signer or guarantor is approved?
01/13/2019
My institution is beginning an on-line mortgage application process and pre-qualification program. I have some questions with what follow up
procedures should be. #1 Individual sees our site and enters a couple of pieces of information, but does not have a completed application. What
should be our follow up? #2 The individual completes the application on-line but does not follow up within the 30 days with other required information.
Is this an incomplete application? Also, on a prequalification, the individual is notified of being qualified and receives letter stating this
online, but does nothing in the allotted time period. Are we required any documentation be sent to applicant? I know this is a lot of questions, but
there are so many variables. We are trying to set up our procedures. Any other information in regards to on-line application and pre-qualifications
would greatly be appreciated.
10/28/2018
HMDA: If a borrower says he does do not want to provide information at the time of initial application, but then they complete the GMI information on the 1003 at closing, what information is reported on HMDA? The updated information or the original information provided by the applicant?
07/29/2018
In our residential mortgage loan application in process, an application was completed (6 pieces of information collected) on 2/28. Our lender mailed out the initial disclosure package on 3/1. This package includes the loan application which contains our joint intent notice. Is this in compliance with ECOA given that the notice was not mailed on 2/28, or is it acceptable to send it on 3/1?
"..3. Evidence of joint application. A person's intent to be a joint applicant must be evidenced at the time of application. Signatures on a promissory note may not be used to show intent to apply for joint credit. On the other hand, signatures or initials on a credit application affirming applicants' intent to apply for joint credit may be used to establish intent to apply for joint credit. (See Appendix B.) The method used to establish intent must be distinct from the means used by individuals to affirm the accuracy of information. For example, signatures on a joint financial statement affirming the veracity of information are not sufficient to establish intent to apply for joint credit."
07/22/2018
1. Do you need a new credit application for commercial loans that are
renewals, extensions or change in terms on an existing account?
2. Do you need permissible purpose to pull a credit report on commercial loan
renewals, extensions or change in terms on an existing account?
06/24/2018
What should the application date on the HUD 1003 be based on, the applications definitions for Reg B, HMDA, RESPA & TRID?
06/10/2018
We are trying to set up mortgage application online. We are having debates on what disclosures we need and how to provide the disclosures. Is it something as simple as sending a PDF or does it require us to follow E-SIGN? If the mortgage is submitted online, do the disclosures need to be sent online?
05/06/2018
What are the requirements if a written adverse action notice of denial is provided to the applicant with a counteroffer and then the counteroffer is denied later on during the process of the application? Is the creditor required to send another adverse action notice denying the counteroffer?
