Most Popular Lending Content
HMDA Reportable Assisted Living Residence
05/17/2004
Is a loan made for an assisted-living residence HMDA-reportable? Also, if more than 4 individuals live in the home, would it be multifamily?
FCRA & Telephone Applications
05/17/2004
Do we have sufficient authorization to pull a credit report when we take a telephone application?
Record Retention for Denied Loans
05/17/2004
Is the retention period for denied loans two years?
Who Should Certify HMDA Data
05/17/2004
HMDA requires an officer of a financial institution to certify the accuracy of the data. The regulation is silent on which officer should certify the accuracy. I believe this responsibility should reside with the Compliance Officer, not Internal Audit. Do you know of any announcements, etc., regarding this, or are you aware of what the "norm" is at other financial institutions?
Usury Due to Fees
05/17/2004
I know that in consumer loans the maximum rate that can be assessed is 18% in many states. My question is, could the APR be more than 18%? We have a specific case where the rate is 15.50% and the APR is 18.285% (there is a fee of $50.00 being financed). Is this a violation?