Most Popular Lending Content
Declined Applications & RESPA Disclosures
08/18/2003
Are RESPA disclosure required within three business days if we decline the application within the three day period and mail the declination letter?
Partnership Name and Filing UCC Documents
08/18/2003
My borrower is a general partnership. They have registered a fictitious name for their partnership. Under UCC article 9 do I record UCC documents under the fictitious name of the business or the individual partner names?
Purchase money open end line of credit?
08/18/2003
We have a customer who is purchasing a condo for investment purpose and is requesting line of credit secured by the condo which will be advanced for the purchase money. Can we do a purchase money open end line of credit?
HMDA & Multi-family Dwellings
08/18/2003
Isa 2-story townhouse building considered 1-4 family or multifamily for the purpose of HMDA?
Multiple Problems With Old Mobile Home Loans
08/18/2003
We currently have about 50 mobile home loans that will be coming due this year and next. These loans were written with under liberal terms, most are on a 15 to 20 year am, some even with 30 year am, with 5 to 7 year balloons. Because of the declining value of the mobile homes, the principal amount coming due is, in many cases, greater than the value of the collateral. Some are with land, some titled. The bank is not anxious to refinance any of these loans (and is not contractually obligated to) and plans to encourage these borrowers to refinance elsewhere, telling them we no longer make these types of loans. We will be revising our loan policy to reflect this. However, if a customer threatens to walk away from the loan, we will refinance at different terms including pricing high enough to ensure at least some principal reduction. The decision to refinance any of these will be made case by case as will the terms of the refi. We'll treat them as work-out loans. In addition to HOEPA coverage, I am concerned about possible disparate impact (probable higher percentage of minorities, families with children, single women,than the general population) and the fact this may appear to be predatory in practice (definitely not the intention). Assuming we can adequately document our "business necessity" for doing this, what is our risk in handing these mobile home loans in this manner?