When we have a borrower in one state but their collateral is located in another state, we will file a UCC where the debtor is located. Some Lenders want us to file in both states just to be safe but then that posed the question, should we be preparing two separate security agreements, one for each state as well? Also, if we have a borrower that has collateral in both states we have been just preparing one security agreement where the borrower is located and still filing two UCC's but we think we should be preparing two separate ones in this case also?
Our financial institution has always issued conditional approvals and views that as our final loan approval for determining if an applicant has withdrawn, etc. Should we have revisited this process with the change in HMDA in 2018?
Can the bank charge a default rate on a single-close, construction-perm mortgage loan during the construction phase if construction is not completed on time? For example, a 9 month construction term with multiple draws has a fixed interest at 4.125%. If construction is not completed at 9 months when the construction phase is to mature a default rate of 4.625% would apply from the maturity of that phase. If it is permissible, does this make the loan an ARM or the increased rate a refi?
Can a third-party conduct the policy review?
What is a final credit decision for HMDA, after which a customer’s wish to not proceed with the application is not reported as withdrawn?