Our financial institution did not originate 100 HMDA reportable closed-end loans in 2019 and therefore is no longer a required reporter for 2020. Can we stop collecting immediately?
Our consumer lending is centralized in a lending unit and not done by our branch staff. The branch will not have access to the credit report to know if the borrower is covered under MLA. Does this mean that we will have to provide verbal disclosure to all applicants in case they are covered borrowers? If so, is there model language available that we can provide to our branches?”
How much "teeth" does UDAAP really have to penalize a bank?
Do the restrictions on loans to executive officers apply to PPP loans?
What exception categories should an automated system track?