On our banking website do we need both the equal housing lender logo AND disclosure? I read that we do but can find one banking website that actually does.
I was asked by a peer about "mortgage bot" application entered on the Internet that were not submitted and not complete to meet the 5 criteria to be a mortgage application (SS#, name, address, loan number and product). I was asked if they require a Reg B adverse action notice. I view them as an incomplete application which technically wasn't even submitted and not Reg B compliant. Am I right these are not applications and do not fall under the Reg B requirement of adverse action notices? They do not fall under HMDA requirements and I do not believe they should be reg B required either. If I didn't have a name or an address I couldn't mail them out even if I wanted to.
Do we need to complete the government monitoring information on the mortgage application taken over the phone or submitted by mail when the borrower has selected "I do not wish to provide"? If yes, do we use surname to make the choice?
I have a real estate loan that the customer checked on the GMI information that they do not wish to furnish this information. We are HMDA reportable. Do I use visual observation to complete the information on the LAR?
What determines the loan application date? If the application is taken face to face, we use the borrower and loan officer's signature date. If it is taken by phone, email, internet, we use the date the loan officer signs and dates the application. Is this correct?
We have a couple of tech-savvy lending officers who regularly post to personal blogs. We have a policy requirement that their blogging must include disclaimers that they are expressing personal opinions only and not writing on behalf of the bank.However, occasionally they may mention a bank product or service ("My bank offers a 35-year fixed rate loan" appeared in one of the blogs last week). Can their blogs be considered advertisements with trigger terms and compliance issues for the bank? Do we have to control what they post?
Are banking lenders required to have blank loan applications (1004) available upon request for mail-in applications, when we only take applications via internet or call center? We currently have them available, but would like to discontinue.
I am working on getting our bank set up to request appraisals through a third party. I was reading HVCC info I found on the internet and saw a section that stated: "The lender shall ensure that the borrower is provided a copy of any appraisal report concerning the borrower's subject property promptly upon completion at no additional cost to the borrower, and in any event no less than three days prior to the closing of the loan." We have not been getting copies of appraisals to customers three days before closing. A lot of times we are waiting to get the appraisal back to get the loan closed ASAP. In what Reg can I find this? I wanted to be sure it was correct before I train our lending staff on this.
As technology shifts, more and more consumers are utilizing the Internet for financial services. That can be good news or bad news for your bank, depending on how you integrate technology into your overall loan process. What are the key factors for success for lending in the Internet age?
Do we need to be concerned if we do not receive a notice of intent to apply for joint credit for internet based loan applications? Our current loan applications have a separate check box to be initialed or this document is signed independently of the loan application.