Ever since CIP we started keeping copies of IDs in our files. Is this OK?
We had the 6 points of information for an application but lost track of the request and took too long to deny it as we were awaiting additional income information from the applicant. What can we do now?
During the PPP loan programs we had many requests, but we were not participating? These are commercial requests and would be subject to Reg B. Were adverse action notices required?
Do we need a policy on providing payment extensions to borrowers?
Customers see on the news that foreclosures and evictions have stopped and borrowers can skip payments. What should we tell them when they ask about this?
When it comes to auto loan rates, we have certain rate discounts that may apply based on an "Engagement Score" for each person. This is determined by our underwriting team and communicated to the dealer for the best rate available at the time the deal is happening so that the correct rate is listed on the contract. The problem is after 5pm when our underwriters go home, we are still getting deals since dealerships are open later. The next day we have a contract signed for the rate the customer qualified for but does not include any engagement score discount.
My question is:
After booking the loan at the rate listed on the contract, may we then adjust the rate down to include the engagement score discount the customer should have received without having to ask the member to sign anything? I assume we could adjust a rate like this so long as it benefits the customer and we document what we're doing and why, but I'm struggling to find a definitive answer in a Reg.
Are rate sheets we send to auto dealers and mortgage brokers CAN-SPAM covered?
We are just a mortgage lender, does this CAN-SPAM affect us?
When and to whom must HUDs SCRA mortgage notice be sent out? We prefer to wait for the 45 day notice we already send.
Is age a prohibited basis of discrimination under the Fair Housing Act?