11/01/2002
10/28/2002
We are still struggling with HOEPA. None of us wants to originate HOEPA loans but if we do, we have the disclosures ready to issue the borrower (3 days prior). Is anyone aware of how many or what percentage of a bank's portfolio can be identified as HOEPA loans before the bank is viewed unfavorably by the regulators and/or Community Groups? Has a benchmark been published or discussed somewhere? Any ideas?
10/17/2002
10/01/2002
10/01/2002
Bankers tend to be peaceable folk. They mind their business, and the financial business of others, day after day.
09/16/2002
Bankers Compliance Consulting Real Estate Loan Matrix. I found on this web site indicates that a closed end home equity loan is not HMDA reportable. I would like to know the reason the author made that decision. I find the reg excludes open end lines of credit only...
09/16/2002
If original loan proceeds were for a business purpose but the loan is secured by mortgage on personal residence, at time of renewing/refinancing that note, does it become HMDA reportable?
09/16/2002
What disclosures are required for a bridge loan to purchase a residence?
09/02/2002
Someone is getting a loan secured by his home to add a pool to his backyard. Do RESPA and the Right of Rescission apply?
08/12/2002
The new changes to Regulation C do not appear to be consistent with HMDA. In the near future we will be seeking both ethnic and race information. HMDA only makes reference to race, not to ethnicity. I do not think that collecting information the same as OMB is justification for an expansion of Reg C beyond that of HMDA. The regulators appear to have gone beyond HMDA. Applicants will be asked their ethnicity AND their race. Hispanics may have no problem with the first question, but how do they answer the next question about race? I think confusion and misclassification will result.Even the example LAR included in the new staff interpretation (page 56) shows a Hispanic couple and he is 'white' and she is 'black'. No direction about the categories have been offered. I do not know how to train the lending staff on these new rules. can anyone get a ruling from the FED about the differences between HMDA and Reg C?