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?
Where can I find information or samples of ECOA self-testing to get started on this project for my bank?
Do I need to worry about font size on the reason for the adverse action for denied mortgage or retail loans?
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?
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or 2 – do we report the accepted closed end mortgage counteroffer as home improvements on our HMDA LAR as a withdrawn request?
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?
Can a cosigner on a mortgage be replaced by another cosigner in a few years through refinancing?
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.
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.
Does the new appraisal rule under the ECOA apply to Home Builders?