Our financial institution originated the permanent financing to replace a construction loan for a new dwelling that was provided by another financial institution. Should we report this as a purchase, even though we did not make the construction loan?
We found an HPML in our audit. There is no escrow set up. What can we do?
If we accidentally deny a loan that has already been withdrawn by the borrower, prior to our credit decision, how should we handle the reporting of the HMDA data on the LAR? Should we report it as withdrawn per Reg C regardless of the existance of the denial letter, or should we report it as denied because there was a credit decision and letter issued and that's the action taken by the bank?
I was reviewing the Flood Question and answer from 7/17/2022 (https://www.bankersonline.com/qa/flood-insurance-conundrum-residential-condo-commercial-building) and was wondering if you could direct me to any publication that has the new flood requirements? Perhaps this is the Flood 2.0 I hear referenced. I had never heard that this condo issue changed and this type of property was no longer a covered transaction.
Our HELOCs are variable rate, but don’t have an “introductory rate." The rate is just subject to change on the first business day of every month. Is that reported on the LAR or do we just put NA since we don’t technically have an introductory rate? Additionally, if we require in the loan contract that the borrower reimburse fees we as the lender paid if the loan is paid off in the first 36 months, does that number need to go under Prepayment Penalty term if we aren’t technically charging a “prepayment penalty”?