When do we disclose Property Value instead of Sales Price?
The CFPB hasn’t been active in fair lending other than mortgages, correct, does this present any challenges?
What features should we look for in an exception reporting system?
Our Executive VP earns a substantial annual bonus. He doesn’t really do any real estate lending, but he certainly talks with many bank customers (often on the golf course) about how the bank can provide various loan solutions, including home loans. Up to this point, he has kept his NMLS ID # and registration current “to CYA”. I’m concerned his bonus may be non-compliant with Loan Originator Compensation requirements. Should I be worried?
If a home equity loan application is not decisioned within 3 business days and preliminary disclosures are not sent out within those 3 business days, does the application need to be canceled and a new application keyed in? That is our current practice and it's a nightmare for HMDA monitoring submissions.