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?
We receive submitted applications from our website that are considered complete per TRID. Upon receiving the submitted application, we attempt to directly contact the applicants by phone or email regarding the application and items needed to make a loan decision.
If we do not receive any contact from the applicant, what are the notification requirements? Should the app be considered incomplete and we send a Notice of Incompleteness and if there is still no response by a certain date, we can close the file? Also, what would the timing requirements be to send the notice and then to be able to close the file?
Denying a Joint Application
If we have a commercial purpose loan to purchase a 1-4 family home for rental, do we use the 1003 application or the standard commercial application?
Are there systems for automating pipeline reports for lenders?
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.
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?
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?
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?
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
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?