What do we report for property value and loan to value if two properties secure the loan, but one was taken in an abundance of caution (AOC) and treated as AOC for the appraisal requirements?
What open-end lines are counted for the HELOC threshold?
As to a loans HOEPA status, are second homes and vacation homes considered not applicable for HOEPA which would make the status code 3 on the HMDA LAR report?
Is there a difference in reporting the total units for two single family homes vs a duplex where both units secure the loan but are contained in the same “property”? Sometimes the duplex will have separate deeds for the units, other times it is on one deed if there is one owner.
Scenario- A customer receives foreign wires for "family support." This customer also received an unsecured loan for a purpose of "family support". The customer withdrawals most of the account funds at casinos in cash and then makes cash deposits after winning money. The lender doesn't have a concern on the loan side. What is your opinion on filing a SAR?