Vendor Guru Q&A - Lending

Latest Lending - FDIC Topics

ECOA Requirements for Conditional Approval Letter

01/01/2017

I am trying to find out what the federal regulators would require we have on a Conditional Approval Letter issued to a borrower. Like the FDIC logo, Equal Housing, etc. What does ECOA require be on this letter?

FDIC Special Situation Clause Multiple Structures

06/17/2013

We have an Ag Loan that has five parcels secured by one loan. When running the flood determination, it shows that two of the parcels are in a SFHA. Out of the five, the two that are in the SFHA have structures on them, a mobile home (permanent foundation) a dwelling, and two equipment/storage sheds. We have flood insurance on the mobile home and the dwelling. My question is are we suppose to have a separate policy for each and every structure on the parcel or can we go by the FDICs special situation clause where it states for multiple structures that secure a loan FEMA does permit borrowers to insure nonresidential buildings using one policy with a schedule separately listing each building or do we have to have a policy for each storage building?

FDIC Lending Limits for Individual Loans 2009-10

06/10/2013

What were the FDIC lending limits for bank loans to individuals during 2009-2010?

FDIC Obvious Error Rule-APR Open-End Credit

01/21/2013

Have you heard of the obvious error rule? The FDIC has recently completed a compliance exam and mentioned the obvious error rule in relation to the APR calculation on open-end credit.

Flood Insurance Violation if Didn't Originate Loan

11/12/2012

We are looking to purchase a portfolio of 2nd mortgages from an unregulated lender, who was not following flood insurance regulatory processes. As a regulated institution could we be cited for flood insurance violations by FDIC even though we did not originate these loans?

Customer Confirmation on Receiving Privacy Notice

08/15/2011

Do we have to/should we have our clients sign/acknowledge that they received a copy our our new Privacy Notice that went into effect 2010? My question stems from a recent FDIC exam.

Conforming Loan Payment Notice

05/30/2011

We have an upcoming FDIC Compliance Exam. In the pre-exam questioning, I was asked if we provide a "Conforming Loan Payment Notice". I thought this was just for the credit card payments but was told that this also involves "payments on residences". I have searched for some type of guidance and have only found information that pertains to credit cards and helocs. In "googling" the topic, I have found several banks that have the disclosure on their website. This is telling me that I have certainly missed something. Could you give me some guidance or somewhere to look further?

Does a Lending Officer have to be Licensed?

02/14/2011

It is my understanding that a Bank Lending Officer does not need to be licensed under the SAFE Act, is that correct? We are regulated by the FDIC.

Collecting Monitoring Info on RE Loan

01/17/2011

We are an FDIC regulated bank. When do we not collect the government monitoring information on a real estate loan application?

Gross Income for Loan Applicants

10/18/2010

We qualify loan applicants based on gross income. Our credit officer says that tax free income from SSI or VA Disability is the gross income and shouldn't be grossed up. I say the income is net and should be. Who's right? If we don't gross tax SSI up, are we discriminating?

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New HPML Rules Defined

12/04/2022

Under the new QM/ATR rules that take effect on Oct 1, 2022, when does a loan become HPML? Is it still based on the 1.5%-1st lien, 3.5%-2nd lien, or does it now go by the new thresholds in the price-based tiers, for instance, 1st lien is less than $68,908 has a 6.5% threshold between the APR & APOR?

When is a new flood policy required on a new loan?

12/04/2022

Does flood insurance need to be in effect the day before a loan closes or the day of is sufficient?

HMDA "Purpose" when paying a tax lien

12/04/2022

We have a HELOC that is going to pay off a tax lien on a dwelling. Should the purpose be reported as "Refinance" or "Other" for HMDA purposes?

Automated exception reports

12/04/2022

What are the potential benefits of automated exception reports?

Auditing Bank Sold Insurance

11/27/2022

We receive submitted applications from our website that are considered complete per TRID. Upon receiving the submitted application, we attempt to directly contact the applicants by phone or email regarding the application and items needed to make a loan decision. If we do not receive any contact from the applicant, what are the notification requirements? Should the app be considered incomplete and we send a Notice of Incompleteness and if there is still no response by a certain date, we can close the file? Also, what would the timing requirements be to send the notice and then to be able to close the file?

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