Most Popular Lending Content
Should our board deny commercial loans?
03/17/2024
Our residential mortgage lending team is very thorough to ensure that the Lending Committee signs-off on adverse action/denial documentation. We are newer to commercial lending. Thus, the Board approves all commercial loans. The commercial lending officer has been given the discretion to decline certain requests before they even get to the Board. The question is more of a compliance/procedural one. Is it sufficient for only the commercial loan officer to sign-off on adverse actions, or should we be obtaining Board sign-off on these as well....under our current approval structure?
Flood Insurance – Do we have enough?
03/17/2024
Our loan amount is $1,000,000. According to the hazard policy, the replacement cost value of the building is $1,500,000. We only have $500,000 coverage on the building and our internal auditor has indicated we need more coverage. Is this true?
We just booked a $525,000 loan to a Director’s law firm. Did we violate Reg O?
03/17/2024
We have a Director who (together with his wife) shares ownership of a law firm. I just learned that we booked a $525,000 loan for that law firm. The loan has a rate and terms comparable to other loans. Is this a problem for Reg O?
Who should own NMLS administration – HR or Compliance?
03/17/2024
Who should manage the NMLS registration for our Mortgage Loan Originators (MLOs)? Is that an HR function, or should compliance do it?
Our EVP just bounced a $1,200 check. What do we do?
03/10/2024
I work in operations, and our Executive Vice President just showed up on the daily NSF report! He has overdrawn his personal checking account by $1,200. What do we do?! Can we pay it or must we return it, and must we charge him our normal fee?