Most Popular Lending Content
Demographic Info Changes at Consummation-HMDA LAR
11/24/2019
For HMDA reporting purposes: An applicant's demographic information is obtained at time of application via an online application process and the data collected is the information input onto the HMDA LAR. But if the applicant changes the demographic info at consummation (at the title company) do we change the data on the LAR from the data collected at application to the data collected at consummation?
Bank Required to Pay Interest on Escrowed Funds?
11/24/2019
Are there any regulatory requirements that a bank must pay interest on escrowed funds? This would be borrowers funds held for construction not tax and insurances.
Signature for Online Loan Application
11/17/2019
We have an online loan application that our members complete. It does not have a signature on it. We use that to pull credit, make the loan and the members come in and sign loan documents. My question is do I need them to complete a loan application in person with a signature or is the on-line application sufficient?
What counts for HMDA reporting thresholds
11/17/2019
Are all transactions that are HMDA reportable counted toward the thresholds?
Right of Rescission Rule Interpretation
11/17/2019
I need some help with the right of rescission rule interpretation. On a refi loan, if the borrowers receive all TRID disclosures on a Saturday but our offices are closed that day so their signatures would have to be made on Monday. My question is, when should the 3 day rescission period begin? On Monday- Wednesday ( based on disclosures received on Saturday) or Tuesday-Thursday ( based on the effective signing date of Monday)? Reg Z states: 1026. 15(a)(3) i. The period within which the consumer may exercise the right to rescind runs for 3 business days from the last of 3 events: A. The occurrence that gives rise to the right of rescission. B. Delivery of all material disclosures that are relevant to the plan. C. Delivery to the consumer of the required rescission notice.
