Where can I get new Fair Lending and HMDA posters for the lobby? I have searched the internet, but I know there has to be something I am missing.
We are considering making loans via the internet. I know CIP and internet security need to be arduous. What other considerations and compliance issues are there?
We receive most of our business from brokers, and most applications are received mainly via fax and internet. I came across some partial GMI information where the customer left some boxes blank, but they did check the sex box. In other instances, the customer checked off the I Do Not Wish to Furnish, and proceeded to check off the sex box, or other boxes, but not all of them. Keep in mind that we have little, and in most cases, no contact with the customer since they are all referred by our brokers. Should we report these as information not provided all across the board, or should we put not provided for the information not provided, and fill in the information that the customer did in fact, check off?
One early indicator of hot compliance topics are the subjects discussed by the Consumer Advisory Council. The CAC committees have planned some interesting topics for their next meeting.
A provision in the FACT Act requires notices to recipients of offers of credit that were prescreened using the consumer's credit report.
I've seen several opinions on this, and I'm hoping you can clarify it for me. It is my understanding based on reading Official Staff Commentary to REG B and REG C , that loan apps taken over the Internet are treated as mail applications. That is also the answer I got in response when posing the question on BOL. However, I've now been told that the usual exceptions for delayed disclosure do not apply to Internet applications. I'm confused, any wisdom you can provide would be appreciated.
FACT Act requires records release for I.D. theft victims
Answer by Mary Beth Guard, BOL Guru
by Mary Beth Guard
Consumers who live in any one of the following thirteen states may request a free annual credit report beginning December 1, 2004:
My question is in regards to Regulation B Monitoring Infomation. We are a non HMDA reporting bank. We have received mixed information concerning the collection of the monitoring information on telephone, mail and internet applications. Does the creditor need to complete the monitoring information on telephone, mail or internet applications to purchase or refinance the applicant's personal residence?
Our Internet branch has proposed a new idea, but I am worried about violating RESPA’s "referral fee" and "splitting fee" regulations. They want to recruit tax preparers (during their off season) to "team up" with our loan officers. The tax preparers would call their tax clients and offer to assist them with their mortgage needs (purchase loans, refinance loans, etc). The tax preparer would then take down personal information (i.e. income, assets, debt, etc) and give the information to their loan officer teammate. The loan officer would then do the rest of the work (i.e. final application, processing, etc). Once the loan funds, it is proposed that the tax preparer would receive 20% of the loan officer’s commission. Is this a violation of RESPA?