While inputting HMDA data, I noticed the census tract number on the flood determination did not match the census tract number found on the FFIEC Geocoding website. Do these need to match and do I need a corrected flood determination?
Is there a Fair Lending risk of disparate impact for a finance company to have a minimum income requirement for applicants?
1.) What date do you use when using the FFIEC calculator to determine a higher priced loan (in-house loan) Is it the application date or is it the date that the loan is to be closed. 2.) This loan is a jumbo loan so would the same rule apply for a different threshold of 2.5 instead of 1.5% even though it is an in-house loan?
Can you tell me the exact web site to find the Average Prime Offered Rate that is used to determine if a loan is HPML?
If we have a 5/1 ARM when we use the ARM table do we use 5 yr APOR rate or the 30 yr? A lot of people are saying we should use the 30 yr versus the change date because the rate can actually go down depending on rates?
Concerning HPMLs, when using the APOR chart provided by the FFIEC, the "term" indicates the number of years until maturity of the note, not the number of years for which the loan is amoratized, as in a twenty year amortization with a five year call. Am I correct with this statement?
When a loan is secured by two properties, which one do I list on the LAR? A customer's existing home and the home he is purchasing are being used to secure the loan.
We currently sell loans to the secondary market. Since the loans take considerable time, we would like to set a minimum loan amount. Will there be any discrimination issues if we change our loan policy concerning secondary market loans to read that we will only process loans for the secondary market in excess of $50,000 or perhaps charge a fee if the loan is under a certain amount?
We were keeping a manual log for HMDA at the beginning of the year and now we have to enter the information on the Loan Application Register (LAR) in the HMDA software. Does it matter which order we enter the information?
Is it required to show proof of training for AML-BSA and/or regulatory compliance? If it is, where is the requirement identified?