Most Popular Lending Content
Flood Insurance – Do we have enough?
03/17/2024
Our loan amount is $1,000,000. According to the hazard policy, the replacement cost value of the building is $1,500,000. We only have $500,000 coverage on the building and our internal auditor has indicated we need more coverage. Is this true?
We just booked a $525,000 loan to a Director’s law firm. Did we violate Reg O?
03/17/2024
We have a Director who (together with his wife) shares ownership of a law firm. I just learned that we booked a $525,000 loan for that law firm. The loan has a rate and terms comparable to other loans. Is this a problem for Reg O?
Who should own NMLS administration – HR or Compliance?
03/17/2024
Who should manage the NMLS registration for our Mortgage Loan Originators (MLOs)? Is that an HR function, or should compliance do it?
Disclosing discount rates
03/10/2024
If our bank does not offer a rate lock program and all of our loans are fixed rate loans, can a buyer purchase discount points to lower the interest rate? If they can, do they have to sign a form reflecting the discount rate or can we just disclose the discount and fee on the loan estimate?
FCRA Signature Required?
03/10/2024
We are transitioning to a new loan software program and have noticed the Negative Information Disclosure document provided at closing is not providing a signature line for the borrower to sign. Our current loan software has the signature line that isn't removable so we have always assumed it was required. I cannot find any information in the regulation that a signature is required. 1) Is a signature required and 2) If it is not required to obtain signature, is it required that we retain a copy of it with the closing package to show examiners it was provided at closing? It just seems odd from what we have always seen and would like to know if we should request a signature line be added.