Most Popular Lending Content
Homeownership Counseling Notice on Repeaters
12/01/2003
We have a borrower that is frequently past due 30 days or more on her conventional mortgage. In all of the Homeownership Counseling material we've read, we can't seem to determine if the counseling letter is necessary every time the loan is 30 days delinquent or not. Is is like the Right to Cure, where it only needs to be sent once, or should it go out every time?
Defining CRA
12/01/2003
According to Anna Alvarez of the OCC, the critical issue of CRA used to be access to credit. Today, the issue is credit at what price.
Where Should a Newbie Compliance Officer Start?
12/01/2003
I have just been nominated compliance officer of a thrift at which I am a new employee (this is my 3rd week). I have 15 years previous banking experience in almost every department but never in compliance. Where should I start?
Calculating APR and Payment Stream
11/17/2003
I am trying to verify for an auditor that we are calculating the APR and payment stream correctly on the final TIL. The loan I am working with is a 3/1 ARM mortgage loan. I disclosed the first 36 payments based on the original contract rate, the remaining payments were based on the current index plus the margin for the balance of the term of the loan. The new rate was actually less than the contract rate since the index is so low at this time. I am confident this is correct and have verified it with our doc prep company - but no one has been able to show me this in writing. I have been reading Reg Z, the Commentary, and anything else I can find - but so far I can only find info on the initial disclosure and not the final disclosure. Where can I find and print the correct procedure for calculating the APR and payment stream that is to be disclosed on the final TIL ???
Existing Customer vs. Former Customer
11/17/2003
This is regarding the USA PATRIOT Act. My question: If a loan customer has an existing loan (no other open accounts) before October 1 and pays that loan off after October 1, can that customer come back later and get another loan without going through the identification process?