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?
Is it required to have a full URAR appraisal done on residential real estate deals exceeding $250,000? Can the bank choose to do a drive-by appraisal instead?
Are reverse mortgages HMDA reportable? For example, a qualified borrower owns a home free and clear with a reverse mortgage loan taken out based on equity in the home. Second example, a qualified borrower has an existing mortgage balance on the primary residence and a reverse mortgage loan is taken based on equity in the home and part of the loan is used to payoff existing mortgage where borrower receives the remainder of the loan.
Can a bank use a tax assessment to determine the value of a home if the value is not more than the tax assessment?
I'm trying to determine the definition of temporary financing. Previous guru answers (in 7/05 and 12/05) have indicated that you must look to the repayment source to determine whether a loan is temporary financing. Repayment sources may include financing from another lender or the sale of an asset. However, in the BOL Tools section, there is a HMDA chart (Consumer and Commercial HMDA Worksheet for Closed End Loans updated 3/3/06) which implies that in order to classify a loan as temporary financing the repayment source can only be outside financing. Which is the more accurate definition? For example, if a bank makes a 12 month interest-only loan to an investor to buy a 1-4 home and the investor improves it and sells it within 3 months (i.e., the sale of an asset and this was documented as the repayment source) is this a HMDA reportable loan?
We just started doing 50 year loan terms and the problem I'm running into is with the Rate Spread calculator on the FFIEC page, it only goes up to 40 years. What is the correct way to determine the rate spread for these loans?
90% of our loan originations (TPO and retail) are submitted with credit, contracts/appraisals, verbals, bank statements, etc. and are conditionally approved for items backing up the credit docs and sometimes appraisal; is this considered a pre-approval?
Now that the 2004 data is out, our concerns about HMDA and the related risk have a little more focus.