I have a question about modifications on our construction perm loans to reduce the rate to sell on the secondary market. We have our construction perms, that after completion and when the loan is closed out, that upon completion of the construction, a “float-down” of the interest rate may be allowed if it meets the guidelines to sell on the secondary market. Does this trigger anything for Reg B or Adverse Action?
If you use a vendor that provides scores from all 3 bureaus and you only use the score/reasons from one bureau for the denial, do you use that specific bureau's name and address or the actual vendor that supplied the report for your adverse action?
We see quite often where lenders agree to pay for or credit back items such as the lenders title policy. This is often done when a lender wants to capture the business of a builder so they offer this as a "perk" to the referrals coming from that builder. I was wondering how other lenders manage to do it without violating any regulations. We wouldn't plan to do this across the board.
Does a consumer lender's NMLS number have to be on a blank application if it is being given to a customer and no other information is collected or given out?
I know that providing a builder a discounted rate on their personal loan in exchange for the builder referring buyers on new construction is a RESPA violation. However, is it also a violation if the bank provides the builder a deal on the commercial loan that was provided to construct the new homes? That loan is a commercial deal and the discount predates the "hoped" for referrals. There is no agreement, more of a hope the builder provides referrals. It's likely a tightrope but appreciate the insight.