Vendor Guru Q&A - Lending

Sharing Exception Reports with Lenders

Latest Lending - Commercial Lending Topics

Stating Draw Feature-Promissory Note

01/27/2019

If we have a Promissory Note that does not state a draw feature, but the Business Loan Agreement does state the draw feature, are we in Compliance? Or would we need to add the verbiage in the Note to be in compliance?

Loan Modification/Extension More Than Once?

01/27/2019

On a business purpose loan, can you do a loan modification/extension agreement more than one time? We have a business purpose loan that we did an extension agreement for, going an additional 12 months. We are wondering if it can be done a second time for an additional 12 months? There is no change in terms, etc., just extension of maturity date.

CRA Small Business w/Sole Prop-Gross Revenues

09/02/2018

If we are making a CRA small business loan to an individual that operates as a sole proprietor and who does not have any schedules as part of their tax return, can we use the personal income as the gross revenues since we relied upon that personal income in making the credit decision, or would this not be a reportable loan?

Commercial Loan-Can Flood Premium be Financed?

08/19/2018

On a commercial loan, can the flood premium be financed?

Upgrade Loan w/o Analyzing Updated Financials?

07/22/2018

If a U.S. Small Business Administration loan is paying as agreed for over 6 months and their credit has improved could you upgrade a loan without obtaining then analyzing updated financials? SBA loans do not have a mechanism in place as conventional lending to be able to require the customer to provide annual financial information to banks.

New Credit Card App for Commercial Renewals?

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?

Building a Tickler Spreadsheet

07/01/2018

Where should we start when creating a tickler spreadsheet?

Modification Agreement to Increase Loan Amount?

07/01/2018

Can you use a modification agreement to increase the loan amount and add collateral on a commercial real estate loan?

Portability of Loan Imaging

05/13/2018

How Portable Is Our Loan Imaging System?

Loan Officer Accountability for Exceptions

05/06/2018

How do you keep loan officers accountable for exceptions?

Premium Content View All

Action Training: Updated Real Estate Valuation Thresholds

By Patti Joyner Blenden

RESPA: How to Violate Section 8

It doesn't matter how strong you think your compliance program is. Someone in the organization may be busy figuring out a way to violate RESPA's Section 8.

Interest Amount Collected for Loan Extensions

02/10/2019

I am auditing loan extensions, and I am coming across several loans where the payment the customer makes after the extension is not bumping the next payment due date. I have figured out that this is due to our loan staff not collecting enough accrued interest. So the customer's payment went to interest, not bumping the due date. My question is : When granting an extension, what interest amount should be collected? What is currently accrued and owed at the time of the extension? or like my Bank is doing taking the per diem X the number of days extending? What is the best practice?

Complete Full Cash Flow? Ability to Repay Rules

02/10/2019

We currently have a consumer in the permanent financing phase of a construction/permanent loan. There was no guarantee we would provide the permanent financing at our bank. When construction was approved the borrower was considered self-employed. He owned two businesses and within the last year has sold a large portion of his businesses and now receives a salary as a manager, rather than an owner. Do we need to complete a full cash flow on this borrower, or could we use the current income received from his salary for ability to repay rules?

Home Improvement Loan- HPML and Escrow?

02/10/2019

I have a home improvement loan for 6 months. On the home improvement loan is it really considered a HPML and I should do Escrow?

Pre-submission HMDA Checkup

02/10/2019

Our financial institution is not a bank or credit union and is regulated by the state. We do not see a choice to enter our regulator on the HMDA LAR. What do we do?

E-Sign Rules When Emailing CD (3 Days)

02/10/2019

Are we required to always follow the E-sign rules when emailing a CD to the borrower 3 days before closing? For instance if we deliver the CD by email (without following E-sign) and the borrower replies that they have received and read the CD, is that sufficient proof that the CD was delivered 3 days before closing? We do not require the borrowers to sign the CD.

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