Latest Lending - FCRA Topics

When/Who is the SCRA Notice sent?

01/12/2020

When and to whom must HUDs SCRA mortgage notice be sent out? We prefer to wait for the 45 day notice we already send.

Monthly Report on New Loans Documentation

12/08/2019

During a review of new loans for the previous month, I found that a joint credit report (husband/wife) was pulled for a new loan that was made to just 1 of them (the wife). The previous loan was a joint loan and a joint credit report was used then How do I need to document this finding in my monthly reports? Along with some additional training for the loan officer, what other things should I be aware of and keep in mind?

Land Trust Department & Retail Banking Documents

12/08/2019

Are there any regulations concerning a Land Trust Department having access to retail banking documents in an institution?

Reporting Commercial Loans to Credit Bureau

11/24/2019

Can we report adverse credit to the credit bureau on a commercial loan and the guarantor if we don't normally report our commercial loans to the credit bureau?

Signature for Online Loan Application

11/17/2019

We have an online loan application that our members complete. It does not have a signature on it. We use that to pull credit, make the loan and the members come in and sign loan documents. My question is do I need them to complete a loan application in person with a signature or is the on-line application sufficient?

Elements of a TRID application

08/25/2019

Can a lender purposely not get one of the six TRID items to avoid getting an application in order to delay the loan estimate delivery date?

"XYZ Data" on Adverse Action Notice

08/25/2019

I have a client (a lender) who orders their credit reports from "XYZ Data" and when a loan is declined, they list Equifax on their Adverse Action Notice (with appropriate address and phone number) and they have now been told that because "XYZ Data" is considered a reseller of credit under the FCRA 603(u) that they should also list XYZ Data (along with its name and telephone number) on the Adverse Action Notice. Is this true?

RESPA - Thing of Value

08/18/2019

RESPA - is it a thing of value if a Realtor puts on their open house flyer a preferred lender's info?

Toughest Regulator

08/11/2019

Which regulator issues the most enforcement actions?

Highest Penalties

07/28/2019

Which violations result in the highest penalties?

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BCFP Updates FCRA Consumer Rights Model Disclosures

By Patti Joyner Blenden

Disclosure of Property Value instead of Sales Price

01/12/2020

When do we disclose Property Value instead of Sales Price?

Rules on Loan Modification on Real Estate

01/12/2020

What are the rules when doing a loan modification on real estate? This loan is secured by 36 acres of vacant land if that matters.

Who should be doing a loan closing?

01/12/2020

Who should technically be doing a loan closing?

Allocate Flood Coverage-Multiple Buildings

01/12/2020

How should a bank allocate flood coverage when multiple buildings are on one loan? Here is my example: 1-4 Residences and we need to start the 45-day process for building one. Loan balance: $800,000 Bldg 1: RCV = $235,000; with previous coverage of $250,000 Bldg 2: RCV = $275,000; with current coverage of $250,000 Bldg 3: RCV = $200,000; with current coverage of $250,000 Minimum required would be $685,000, which is bldg 1 = $235,000, bldg 2 = $250,000, bldg 3 = $200,000 If the $685,000 can be allocated any way, what amount would be used for building 1 so as to not be insuring too much?

Real Estate Property Taxes on Closing Disclosure

01/12/2020

I have a refinance loan closing and I have to pay the real estate property taxes that were due on 7/1- summer taxes. Where should I put them on the Closing Disclosure, In section F-prepaid or is it okay to put them in the payments and payoff section (page 3) on the CD?

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