08/30/2020
If a home equity loan application is not decisioned within 3 business days and preliminary disclosures are not sent out within those 3 business days, does the application need to be canceled and a new application keyed in? That is our current practice and it's a nightmare for HMDA monitoring submissions.
06/07/2020
If joint applicants live in same address, do we still need to provide separate notice (i.e. 2 FCRA notice) or can we send 1 notice and since they both live in same address, that would meet the requirement?
04/19/2020
I recently had a debate with a former colleague regarding the Mortgage Loan Originator (MLO) e-signature on the initial 1003 sent to the borrower for initial disclosure purposes. This colleague stated that the MLO had given consent/permission to the processor to complete the MLO's e-signature due to the expeditious nature of the loan in question as the MLO would not be able to get to it for a few days. Keep in mind that it was only the e-signature of the MLO on the initial 1003, not the borrower.
This individual was not being fired or resigning as they would be returning within 2-3 days but the loan needed to be moved into underwriting.
I was not to sure about this. Does this constitute a violation, or is it considered fraud?
02/02/2020
Our loan officers pull clients credit reports and input the information in our LOS. Not all six items that make up an application for a home loan have
been provided. My question is, do we still send out a "Notice of Incompleteness" to the client if the only thing that was received in the
loan file was the credit report and the loan has been in our system for 30 days with the property marked, "TBD?"
The way I read Reg B is that you only send out the NOI once it is considered an application. So if these are not considered an application but you
obtained credit, would we not have to send some sort of documentation/NOI because the score is good enough to move forward?
01/26/2020
This question has come up before but I have not seen a clear answer. If the application is NOT taken face to face, how should the collection method
questions be answered for HMDA? Code 3 (NA) is only supposed to be for applications where the requirement to report the data does not apply to the
covered loan.
We would use code 3 on applications where it is an entity. Code 2 (not based on visual observation) would be the only choice that would make sense.
What are your thoughts?
12/29/2019
Do you know when the new revised Uniform Real Estate Application 1003 will be issued?
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.
