Most Popular Lending Content
Can you give the customer a copy of credit score/credit report?
08/18/2003
Can a Loan Officer disclose a customers credit score with them? Can the Loan Officer give the customer a copy of the credit report?
FFIEC and the Reclassified MSA Branches
08/18/2003
On June 6, 2003, FFIEC reclassified some of the MSA branches. The branch getting us into the HMDA reporting was dropped (which means we are no longer report HMDA ....hurrah.....) My question is, how do we report the information collected prior to June 6, 2003. Do we continue to collect HMDA information past the June 6th date? And what do we report to HUD next year? I have sent this question to HUD, FFIEC and FDIC (our regulator) and I have received no guidance. I need guidance. Can you help?
ARM (LIBOR) Interest-only Loan Calculation
08/18/2003
This has to do with ARM (LIBOR) interest-only loans. On our final TIL disclosure schedule of payments it shows that the amount of payments have decreased. This is due to historical low interest rates. Obviously, the calculation or formula is not shown on the TIL. However, in order for our IT department to program our system to calculate this type of loan product, I need a basis for the calculations. My question to you: is there a particular Web site that shows exactly how to calculate the ARMS interest only based on LIBOR index (decrease payments)? I've spent the past few days surfing various Web sites (including OTS, OCC, and Treasury) regarding this question to no avail.
Is a tax monitoring fee a pre-paid finance charge?
08/18/2003
Our institution would like to charge a one-time $ 75 fee to our mortgage customers for our service of monitoring whether or not their property taxes are paid over the life of their loan. Is this a pre-paid finance charge? Are there other compliance issues we should be addressing?
Dealer Loan Portfolios & Fair Lending Concerns
08/18/2003
The bank I work for has a huge dealer loan portfolio and works directly with a large number of dealers. We recently rolled out a "Preapproved Program" in which dealers are allowed to pre-approve loans on the bank's behalf using bank issued guidelines. They arealso considering expanding the pre-approved program to include our mortgage broker relationships. I have been searching for articles that discuss indirect loans and fair lending concerns and cannot locate any. Can you recommend any resources I can use to develop a management presentation that outlines the "fair lending concerns" associated with these activities? In addition, is there a checklist any where that can be used as review outline of fair lending issues/concerns to consider as management continues to develop new and/or more competitive loan programs?