Is a loan secured by a note receivable, which is subsequently secured by real estate with structures on it a designated loan for FDPA? We have had some debate about the fact that the banks collateral assignment has been recorded in the real property records which puts us in the chain of title and therefore the loan should be designated. And is it a flood violation if the borrower has proof of flood insurance but the bank is not listed as loss payee?
If you deny an application because the applicant cannot get clear title on the property what reason would you use on the denial notice (would you create an “Other” reason)?
Is use of the new rules mandatory?
If an applicant chooses not to provide the borrower demographic data do we still collect it based on visual observation and surname?
When are the new rules for private flood insurance effective?