Should we have one or more employees that are designated to handle all customer complaints? Should all complaints be referred to them no matter who initially receives the complaint?
For telephone applications, we ask the caller if there will be a joint borrower and who that will be. Would checking the joint applicant box on our loan system at the time of the verbal application be considered enough evidence to show joint intent?
During the underwriting process, what if the bank determines that a guarantee will be necessary on the loan, are we permitted to require the spouse to guarantee? For example, in evaluating the application, the bank discovers that most personal assets are jointly owned, or the spouse contributes significantly to the income stream, and therefore the applicant would not be individually creditworthy.
We have an existing customer that is a home builder. Our customer is
partnering with a new individual to purchase and develop a small subdivision.
Our preliminary due diligence (do not have a formal application, run a credit
report or OFAC) reveals the new individual was convicted of a felony (failure
to complete a Form 8300 with a prior mortgage company he owned) and served 7
months in federal prison. Information shows he was well aware of what he was
doing in order to facilitate the laundering of money for a drug dealer
through his attorney.
Can we decline a loan request based upon an individual’s criminal past? We
are also trying to measure Fair Lending at the same time here.
How much flexibility do we have in defining “an application”?
We are offering loans via a mobile app. Can we accept scans of IDs as that is a good way to help verify we are engaged with our customer, by having them send us a picture of their ID using a smartphone.
What is the proper way to respond to an inquiry about a loan?
Can a bank require a co-signer on the first loan a borrower has ever had even if they qualify on their own?
I’ve heard with the new law our HMDA requirements will be like 2017, is that right?
What is REMA?