When a Commercial Department is presented with an opportunity to provide a term sheet for a commercial loan - prior to receiving a loan application - is this request to be considered a loan application? Does HMDA reportable issue apply if the bank never received a loan application and there is no loan decision?
When a commercial department is presented with an opportunity to provide a term sheet for a commercial loan - prior to receiving a loan application - is this request to be considered a loan application? Does a HMDA-reportable issue apply if the bank never received a loan application and there is no loan decision?
We have a member at our credit union that wishes to increase their home equity line of credit in order to purchase a rental property. The line of credit is on their primary residence, and would remain so. Would this be considered a commercial loan (and therefore require an originator with commercial lending authority), where the purpose would be to provide rental income? Or would it not, considering the actual collateral of the loan is the member's primary residence.
In Commercial Lending, an entity as the borrower does not require HMDA. Recently, my loan officers have been making the "usual guarantors" as Co-borrowers instead. Do I now need to complete this as a HMDA loan?
My bank does mainly commercial lending. We have a couple of 'refinance' scenarios that we have questions on. We had a loan approved in 2010 - the purpose was refinance business debt and my bank was taking a subordinate lien position on the principal's residence. After the bank's approval the borrower did not approve our terms and my lending officer did no further investigation so I do not know if the loan we were paying off was secured by a lien on their personal residence or not to know if it falls under HMDA. How do we make the determination as to if it is HMDA or not?
Recently the Department of Labor came out with rules regarding mortgage loan officers. We currently have an employee whose primary job is in commercial lending. He also does some mortgage lending on the side. Would we have to evaluate his salary as a part of the new rules? Because he doesn't primarily work with mortgages, would he be exempt from this?
Our commercial lending area is using the website to advertise their products. As commercial lenders, they maintain they are not held to the same requirements as our home mortgage lenders. One example is the Equal Housing Lender logo. It isn't on the web page and we believe it should be in order to be in compliance. Who is right?
Can you tell me the definition of a thrift? I was recently hired by a financial institution that is classified as a thrift and I have had customers ask me what a thrift is.
How long does the commercial lending department need to keep records of declines, withdrawals and paid loan files?
I work in commercial lending and we have several construction loans to builders that we are now having to extend the maturity date and modify the payments to P and I (principal and interest) because the homes are not selling. Is this HMDA reportable?