We are being sold to another bank. We currently report to all four credit bureaus. The new bank only reports to one. We do mortgage loans, but all are sold on the secondary market. We do not do any student loans. Is there any reason why we have to report to all four bureaus?
I received a private flood policy for a commercial loan with 24 structures located in a flood zone. The coverage amount is over $3 million more than what is required. However, based on the definition of "Private Flood Insurance," the policy does not meet all of the requirements. Are there any best practices or additional guidance besides the proposed rules that are not finalized? We are a member in this syndicated deal and the agent bank is willing to accept the risk of not having all of the required items. Given our
bank must perform our due diligence separately, I am not comfortable accepting the policy as is and am looking for guidance on something I may be missing.
When there is a mortgage on a non-residential condo unit and the property requires flood insurance which is provided by the condo association, what is the best practice for the mortgagee on the unit so as to be notified if a lapse in coverage occurs? Our borrower has the inside of the unit covered for flood, but the condo association is not otherwise providing us with information on the common areas its policy covers.
Our original Loan Estimate shows the loan as construction but it was in fact a refinance. Is this correctable on a revised Loan Estimate?
We mailed the borrower’s Loan Estimate and they emailed us that it was received and they want to proceed with the loan. Can we act on this emailed notice?
How do you calculate flood insurance on a duplex where the borrower is purchasing both and they will live in one as their primary residence and the other side will be a rental? There will be two separate purchase loans; one for the primary residence and one for the rental. Does it make a difference if it is titled differently vs titled the same?
We are going to finance the purchase of a mobile home. Would this be HMDA reportable?
Is there a difference between a manufactured home, and a "pre-cut, tilt-wall" or "panel" home?
What approach do other lenders take when a property is not in a mandatory purchase flood zone, but "maps-in" during the origination of the loan? In some institutions, we've had a process to verify the flood zone prior to close, but others have allowed loans to close and immediately put the loan into the 45-day flood letter cycle?
On an HPML, can the customer cancel their escrow account if the loan has been on the books for more than 5 years?