Most Popular Lending Content
HMDA Race & Visual Observation
08/02/2004
It is clear under the new rules that both the race and ethnicity sections must be completed when required. However, in my part of the country (Texas), the vast majority of Hispanics are of Mexican descent. Based upon the OMB racial definitions, there does not appear to be a single race category that applies to most Hispanics. And, most of the time, from what I am seeing, Hispanics will not check the race category, leaving loan officers with the responsibility of using the OMB definitions (per the FFIEC's instructions), which provide no help. What do you suggest a bank should do in selecting the race for Hispanic applicants?
HMDA Borrower is a Trust
08/02/2004
HMDA loan-applicant is a is a living trust (husband and wife). Is the correct monitoring data answer "NA" or should the husband and wife complete the form as individuals?
Conflicting Rules
08/01/2004
Question: When one office of a regulator says one thing and another office in the same regulator says something that conflicts, what do we do?
Preparing for the FACT Act: A To-Do List (Activity List)
08/01/2004
During the next six to ten months, the FACT Act provisions will continue to take effect.
Short Term Loan
08/01/2004
Question: If we are making a temporary loan, such as a bridge loan, is it subject to rescission?