Pertaining to the acceptance of private flood policies, my question is in reference to the statement found in the OCC Federal Register (vol. 84 no. 34 pg. 4955). “Specifically, the proposed rule … to mean an insurance policy that: (1) is issued by an insurance company that is licensed, admitted, or otherwise approved to engage in the business of insurance in the State or jurisdiction in which the property to be insured is located, by the insurance regulator of that State or jurisdiction or, in the case of a policy of difference in conditions, multiple peril, all risk, or other blanket coverage insuring nonresidential commercial property, is recognized, or not disapproved, as a surplus lines insurer by the State insurance regulator of the State or jurisdiction where the property to be insured is located.” Please confirm which state the licensure would be verified in. Is it in the state the real property is located in, the state in which the agent is, or the state in which the insurance company is located? For example: assume our real property is in Louisiana, the agent is in Texas and insurance company is in Massachusetts. My interpretation of this statement is we would verify licensure in the state of Louisiana, but it's confusing.
When collecting HMDA information on declined consumer loans, what is the source document for verifying the number of units? Are we OK to use the application where the client indicates the number of units since we do not have an appraisal or do we need to verify using a tax card? Since it's a decline I wasn't sure what the source document would be.
We have a commercial loan where the borrower took out a loan to reimburse himself for the purchase of an investment property. The property was already owned by the borrower at closing and none of the proceeds were being used to pay off any other loan or to improve this home. Would this be HMDA reportable, and as what purpose?
Which regulator issues the most enforcement actions?
What regulatory disclosure is required for refinancing a commercial mortgage loan?