Most Popular Lending Content
Permissible Purpose to Access Credit Reports
09/06/2004
Under the "permissible purposes" rule in the FCRA, if a customer applies for joint credit but only one applicant is present to sign the application authorizing us to obtain a credit report, do we have a "permissible purpose" to obtain a credit report on the absent applicant? Do we need the absent applicant's signature before obtaining the credit report? Is the same thing true for deposit accounts when checking with ChexSystems? I have not been able to find anything indicating the customer is required to sign giving permission to obtain the credit report.
GMI Regardless of Lien Position
09/06/2004
Do we collect government monitoring information on a home equity loan, regardless of lien position?
Efficiently Documenting Collateral - TREEV
09/06/2004
Our bank has many commercial customers who secure several loans with the same collateral - such as large value properties. Today we make multiple copies of critical documents and store them separately with each loan. Is there a way to simplify the process so we don't need to make multiple copies? Also, how can we be sure that we have the most recent appraisals and insurance information without having to manually research each loan secured by that collateral?
Signature to Affirm No Rescission
09/06/2004
How many banks require the customer to sign an acknowledgment that they have not exercised their right of rescission before funds are advanced? We raise the question because the regulation does not require such an acknowledgment; however, we have been told that unscrupulous lawyers can use it as a loophole.
Maintaining Bank-Paid Insurance Premiums
09/06/2004
We have two customers at our institution who are delinquent on their mortgage loans and have now filed bankruptcy. Each carries mortgage life and disability insurance on their loan with the monthly premium included in the escrow portion of their payments. We remit the premium monthly to the insurance company. Do we have the right to cancel these policies because of nonpayment to us?