HMDA - Number of key fields - Out of the 110 data fields, I need to verify the number of key fields for the HMDA Data Fields. I think that the number is 37 but I just want to be certain.
I am new to lending compliance and have an advertising question. My bank wants to advertise the following: "Enjoy our special 20-year financing offer. Ask us for details." I am of the opinion that "20 year financing" is a trigger term and therefore requires APR, down payment and repayment terms. My predecessor disagrees because an interest rate is not quoted. Along the same lines, if an advertisement says, "15 and 30 year fixed rate loans available" would we have to disclose rate and payment options for both terms assuming this is a trigger term?
I have always been told that if you have a bonefide discount fee (point) that the discount fee does not need to be included in the APR. It seems as if everyone is including in the APR (the discount fee). Is there a way to not include it in the APR?
We have been told that an “As Is” value is required for “in-house” loans, but we have had several of our appraisers argue this requirement and say that USPAP does not require this. Is this a requirement and what do I tell my appraisers?
We recently had a change in staff and are cleaning up lending procedures. In doing so we noticed that our flood procedures do not include insurable value. We only calculate flood insurance on the Maximum allowed or the loan amount. Basically we could be requiring the customer to obtain more insurance than what is needed. I would argue that we are in compliance; however, what other risks do you see in not using the insurable value. We are not sure why are former employee never used insurable value.