When we order flood determinations, we also get life-of-loan monitoring for an extra fee. We pass it along to the borrower. Is the determination fee a finance charge?
We are making a HELOC secured by a home in flood zone. Do we have to escrow the flood insurance premium?
Is flood insurance required on property taken as an abundance of caution?
We have been having a terrible time getting our borrower to provide evidence of flood insurance. We are all getting frustrated. Today she finally brought in a binder showing an adequate amount of coverage. Can we close tomorrow?
Will Loan Production Offices help in fair lending if we decide to close branches?
We told our commercial applicant that his building is in a flood zone so he needs to purchase flood insurance. He hired a registered professional engineer and brought in an elevation certificate showing the lowest floor is above the Base Flood Elevation. Can we accept it? He is threatening to take his loan elsewhere if we don’t.
The CFPB hasn’t been active in fair lending other than mortgages, correct, does this present any challenges?
How are regulations that are not the fair housing act, fair lending regulations?
If UDAAP is going to be used to enforce “fair banking” will we see less of ECOA, the FHA and other anti-discrimination regs and laws?
How much "teeth" does UDAAP really have to penalize a bank?