It has just come to our attention that we have a consumer construction loan and on the cost breakdown there is a line item labeled "New Construction Realtor Referral Fee." The Realtor is charging a 1.5% referral fee for referring the contractor to the borrower. The contractor is charging the borrower for the fee. Is this a violation of RESPA Section 8? Contractors are never mentioned in section 8, but Realtors are. This is apparently happening more than we knew, but the fee is generally wrapped into the builder's fee and not its own line item, so the bank was not aware of the problem.
We have a customer that is a victim of fraud. The customer called several different credit reporting agencies to get information and received several different answers regarding credit information. The customer wants us to pull a tri-credit report for them. Would this be a permissible purpose to pull the credit report?
How does a bank best create an assessment area map and map of their county showing branch locations and census tracts for its CRA public file?
Our bank is currently scrubbing our loans in Call Report Code 1A2 - Other construction loans and all land development and other land loans. The following are questions to decide whether some loans are in the right bucket: - What classifies as farmland vs raw land? - Are loans secured by timber tracts considered farmland? - What call report code do trailer parks belong in? - Are they considered "other" land and belong in 1A2 or can it be classified as a 1E2 since it is an income producing property?
How can a bank track disclosure exceptions?