Latest Lending - ECOA Topics

Disclosures for Mortgage Application Online

06/10/2018

We are trying to set up mortgage application online. We are having debates on what disclosures we need and how to provide the disclosures. Is it something as simple as sending a PDF or does it require us to follow E-SIGN? If the mortgage is submitted online, do the disclosures need to be sent online?

Info of Samples of ECOA Self-Testing

03/11/2018

Where can I find information or samples of ECOA self-testing to get started on this project for my bank?

Reg B- Font Size on Reason for Adverse Action

11/26/2017

Do I need to worry about font size on the reason for the adverse action for denied mortgage or retail loans?

When Does An Oral Inquiry Become An App

11/13/2016

At what point does an oral inquiry for a loan become an application, thereby requiring an adverse action letter if denied? For example: 1. Bob asks about the bank’s car rates and terms for a 5 year old automobile. When he is answered he decides not to proceed. Was this an application that requires an Adverse Action Notice? 2. Sue calls and says she wants to talk about a Home Equity LOC. But the banker explains that it does not offer that loan product. Has Sue applied for a HELOC and required to get an Adverse Action Notice, or was it simply an inquiry that requires no further action by the bank? 3. John says he wants a loan to start up his own business, but mentions he does not have a job currently and filed bankruptcy last year. The loan officer tells John that he won’t be able to help him out. Has John applied for a loan and an Adverse Action notice is required, or did John simply inquire about a loan and no further action is necessary by the bank? 4. Peggy asks for the rate and terms of an automobile loan. The loan officer provides her with the information, then asks how her credit looks. If she tells him it’s not good, and the officer says he wouldn’t be able to make the loan, has Peggy applied and is she due an Adverse Action notice?

HMDA & ECOA: Rejected closed end counteroffer

05/30/2016

We have an application that started as an $18,000 home equity line of credit (HELOC) for home improvements. The bank counteroffered the applicant a closed end mortgage in the amount of $8,671 and they accepted that offer and their government monitoring information was then collected and disclosures were sent. Days later the applicants called back and stated after further consideration they were not comfortable with doing the closed end mortgage, which raises a couple questions: 1 – do we go back to the original request of a HELOC and deny the HELOC application for excessive LTV listing our counteroffer; or 2 – do we report the accepted closed end mortgage counteroffer as home improvements on our HMDA LAR as a withdrawn request?

Notification Required After Conditional Approval?

10/11/2015

Is a notification required to the consumer after 'conditional approval' has been granted and the consumer does not respond back with the necessary information or documents?

Replace Consigner On Mtg Through Refinancing?

08/02/2015

Can a cosigner on a mortgage be replaced by another cosigner in a few years through refinancing?

Reg B Joint Credit 90 Day Extension

07/26/2015

Does the Joint Credit under Regulation B applies to a 90 day extension of an existing loan? We are only extending the maturity date to allowed additional time to analysis and review.

New ECOA Valuation Rule Apply to Home Builders?

06/09/2014

Regarding the new ECOA Valuation Rule that amends the appraisal provision of ECOA's Regulation B. Would it apply to home builders? I can't find anything in the regulation that it wouldn't.

ECOA New Appraisal Rule Apply to Home Builders?

06/02/2014

Does the new appraisal rule under the ECOA apply to Home Builders?