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Latest Lending - FIRREA Topics

FIRREA Rules for LTVs on Commercial Real Estate

12/17/2012

The commercial loan officers at my bank have a general understanding of FIRREA however one among us believes that FIRREA may dictate LTVs on commercial real estate - in particular a vacant commercial lot. Is this true, If so, where can we find an explanation?

Reg Y - Forgoing the FIRREA Appraisal

07/21/2008

Under Regulation Y Sec 225.63(a)(2) there is an exception if a lien is taken in an abundance of caution. Would this include a lien taken on an existing home as additional collateral for a construction loan that will have a FIRREA appraisal on new construction, but is not adequate collateral so we are taking the existing home? Can we forgo the FIRREA appraisal on that collateral taken in an abundance of caution?

Review Appraisal - FIRREA Violation?

02/18/2008

If a review appraisal is completed by the same appraiser who did the original, is this a violation of FIRREA? Does the review appraisal have to be from a different apprasier?

FIRREA Business Loan Exemption

05/08/2006

FIRREA allows an exemption from a state licensed or state certified appraisal for business loans of $1M or less that are not dependent upon the sale of, or rental income generated from the collateral real estate as the primary source of repayment. A "business loan" is defined as an extension of credit to "any" corporation or other business entity. Would this exemption be applicable to a non-profit corporation (e.g., an incorporated church)?

Separating the Appraisal and Evaluation Functions - Mary Beth Guard

09/27/2004

Separating the Appraisal and Evaluation Functions
Answer by Mary Beth Guard, BOL Guru
Guru BIOS

HUD's Proposed Revisions To The GFE

08/01/2002

HUD has published a proposal to make significant changes to the Good Faith Estimate that lenders issue within three days of taking an application. HUD calls this a "simplification" of the GFE.

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Action Training: Updated Real Estate Valuation Thresholds

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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?

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?

Opening Acct. for Campaign Fund- Use SSN?

12/08/2019

In the state of Texas, when opening an account for a campaign fund, are we required to have a TIN or can we use a SSN?

Equal Housing Lender Logo on Business Card?

12/08/2019

Does a mortgage lender's business card require an Equal Housing Lender logo?

Deed of Trust Construction Materials/Flood

12/08/2019

We have an interim construction loan that the real estate is in flood zone AE. Our Deed of Trust lists the real estate and the construction materials including drapes. All of the construction materials listed are covered under the buildings flood insurance, however the drapes are not. The plans and specs for the construction does not list drapes. Do we have to require contents coverage just to cover the drapes since it is listed in the Deed of Trust?

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