Most Popular Lending Content
Under the Revised HMDA Regs
10/06/2003
With the HMDA revision, I have read that the new definition of refinancing is a transaction in which a new obligation satisfies and replaces an existing obligation, where both the existing and the new loan are secured by a lien on a dwelling. However, in the revised reg., it says that for coverage purposes, a refinance is when the existing obligation is a home purchase loan and both the existing and the new obligation are secured by first liens on dwellings. For reporting purposes, both the existing and the new obligation are secured by liens on dwellings. What is the difference under the revised reg between coverage purposes and reporting purposes? What types of loans should be reported as refinances in the future?
CIP and Indirect Lending
10/06/2003
We are a little confused regarding CIP and Indirect Lending. We do Indirect Lending with a few dealers. They use a generic form for the loan agreement with the loan assigned to the Bank. We have an agreement with the dealer. The loan is not made until the Bank gives approval. Would this be considered a tranfer of assets and no CIP required or the dealer working as our agent?
OCC Sings Fed's Song
10/01/2003
OCC's Chief of Staff, Mark Nishan, spoke to the Midwest National Bank Conference in St. Louis and delivered a strong message on corporate ethics in banking.
Predatory Lending: Pre-empting Predators
10/01/2003
Federal regulators have some fancy tools and the Comptroller of the Currency plans to use his. The tool in question is federal preemption.
OCC Preempts Georgia Law
10/01/2003
The OCC has published its conclusion that national banks are not subject to the Georgia Fair Lending Act (GFLA"). The GFLA contains strong measures designed to prevent predatory lending.