12/01/2002
11/01/2002
The penultimate session at PCi's CRA and Fair Lending Colloquium was a discussion and debate on payday lending.
11/01/2002
Paul Smith, Regulatory Counsel for ABA, led the Washington Update panel at PCi's CRA and Fair Lending Colloquium. Predatory lending was the leading topic.
10/07/2002
I have a RESPA / Reg Z question that I am hoping Lucy Griffin can help me with. In some cases, a lender will waive or reduce a fee on a RESPA-related loan. When this is disclosed on the GFE and HUD-1 or HUD-1A they will list the full fee and then insert a lender credit on one of the empty lines in Section L on the form(s). Sometimes they determine up front that they will waive or reduce a fee, but they still list the full fee with the lender credit as a separate line item. Sometimes the fees they decide to reduce or waive are prepaids (for example points). The APR is calculated using the full fee in the amount financed calculation. Is there a problem with recording fees this way - either with RESPA or Reg Z? Based on Q12 in OCC's AL 2000-5, it seems that this would work basically like a coupon and would be okay, although it is disclosed in Section L rather than Section J (I'm not sure why they recommend Section J since there isn't one on a HUD-1A).
10/07/2002
It would be helpful if Richard Insley could expand on his answer to "Disqualifying Loans based On Prior Bankruptcy". His last sentence: "Exceptions can lead to unpleasant encounters of the Reg B. kind." could use further explanation. We do make exceptions to your 7 years no bankruptcy rule, depending on the circumstances and type of bankruptcy. For example, if it was medically related or chapter 13, we will make an exception. Would it be better to have a set policy for medical or chapter 13 bankruptcies?
10/01/2002
Bankers tend to be peaceable folk. They mind their business, and the financial business of others, day after day.
09/16/2002
Someone asked me a question regarding changes to the Fair Lending Act and TruthInLending Act that will be effective 10/4/02. I was not aware of any changes. What, if any, are they?
08/12/2002
I am brand new to the Banking Industry as a Compliance Analyst. I've been asked to design fair lending, reg z til and respa test programs. I have no idea where to begin...are there any templates out there that can get me started?
06/03/2002
We have an affordable loan program that is specifically geared towards minorities, females, household incomes that are less that 80% of HUD's MSA Median Family Income, a property located in a low income census tract or that is considered mostly minority and a first time homebuyer that does not meet any of the above -- any of these individuals will receive an 1/8% rate reduction. Are there any fair lending/CRA issues that we need to be concerned about?
05/06/2002
Our institution wants to develop a behavioral scorecard for delinquent accounts for collection purposes. The only information I can find regarding scorecards and fair lending deals with evaluating creditworthiness in making the initial loan decision. Is there any information about reevaluating credit once it has gone bad? They want to use age as an attribute. Do I need to be concerned?