Latest Lending - Credit Report Topics

HUD's Proposed Revisions To The GFE

08/01/2002

Notification Requirements When Pulling Credit Reports

07/15/2002

Our Consumer Lending unit received the following response to a recent audit. "According to the regulation, a bank may pull a credit report on a person if they have a permissible purpose. An application for credit is considered a permissible purpose. When the Contact Centers take applications over the telephone (he doesnt mention anything about the Internet) they are only speaking with one of the applicants, but if the application is joint, credit bureaus aer obtained for both applicants. Without talking to the joint applicant, the bank can not be sure that the second individuaal is aware of, or wants to apply for a loan. If a co-applicant does not want to be an applicant on the loan, the Bank would not have a permissible purpose for obtaining the credit bureau. It is recommended that the Consumer Lending Dept require that all parties on a loan application be made aware that a credit bureau will be obtained." I realize that this is only a recommendation, but this team believes because a compliance auditor wrote this, they need to act on this recommendation. Is there some litigation that suggests we need to do this? I simply can not find anything, anywhere that states we are required to verbally inform a co-app that we are going to pull a cbr. What am I missing here? Is this a business decision and if so, based on what? If its written somewhere, I would like to see it. What are other institutions doing?

Finding Finance Charges

07/01/2002

Will Your Collateral Remain Insured?

04/17/2002

Using Average Costs For Loan Fees

03/11/2002

When we close a loan on the mortgage side we charge a $30 credit report fee. The actual fees are between $16.50 and $50. We averaged our actual costs and came up with $30; therefore, we are charging more for some customers and lessfor others.My question is - is this practice permissible or do we have to charge actual costs? Can you point me in the right direction on this issue?

Lending Disclosures at a Glance

03/01/2002

Refunding Non-Refundable Fees

02/11/2002

Our bank charges a non-refundable $350 mortgage application fee to all customers. If the loan is made, the settlement sheet reflects amounts paid outside of closing from this fee for the appraisal, flood report, and credit report. Recently, in a refinance situation, the borrower exercised his right of rescission and requested the return of his application fee. <a href="http://www.bankersonline.com/regs/226/226-15.html">226.15</a> and its <a href="http://www.bankersonline.com/regs/226/regzcomm.txt">commentary</a> indicates to me that we must return the whole fee. Is this correct? If so, are we ok in retaining the fee in a purchase application where the request is declined?

Privacy For Agricultural Customers

11/12/2001

BOL's Servicemembers Civil Relief Act Page

09/27/2001

It's Time To Fix RESPA

04/01/2001