06/20/2005
We sent out a preapproval offer for a Home Equity Line of Credit, including the FCRA prescreen offer disclosures. The consumer calls and lets us know that he is now unemployed. He still meets the credit criteria we used to prescreeen him for the offer (his credit score is still good). Do we have to give him the HELOC? Or can we deny him because he no longer has the ability to repay the debt?
06/06/2005
If a borrower owns their property free and clear and is applying for a (1st) mortgage to finance their child's education, would this transaction be HMDA reportable as a refinance? Or does it not qualify as a HMDA refinance because it is not replacing an existing loan?
05/23/2005
What are the benefits of refinancing a mortgage, with respect to getting some cash, in the form of line of credit or equity?
05/01/2005
Ever since its implementation, the efforts to develop and implement a Customer Identification Program have been fraught with questions.
02/01/2005
Following the old advice of something old, something new, the OCC has issued guidelines on establishing standards for national banks on mortgage lending.
01/17/2005
If the HELOC is closed simultaneously with the purchase money mortgage and the HELOC is fully funded at that time, my understanding is that it would not be subject to rescission. However, if a payment is paid on the line and later another advance is taken, is that next advance rescindable? Can the notice be given to the borrower at closing for future advances? Should specific language be in the disclosure noting that rescission does not relate to the initial advance?
01/17/2005
Are closed-end home equity loans HMDA-reportable by national banks?
11/29/2004
What fees are included in the Section 32 home equity loan?
11/15/2004
Have you ever heard that a bank cannot tie a 1st mortgage loan secured by a borrower's residence to Prime?
11/01/2004
We are an FDIC regulated bank and are considering starting to offer HELOCs. What are the required disclosures and are there good "cheat sheets" you could recommend? I am fairly new to compliance and would appreciate some help in understanding this product.