In the past if we did not classify a loan as a home improvement loan we were not required to report it on the loan application register. Now I hear that as of January 1, 2004, all home improvement loans are to be reported regardless. Is that the case?
Situation: husband and wife submit a joint loan application. Husband's credit is fine, wife has poor credit. The loan is unacceptable "as is", however, if the wife is removed from the application, the husband qualifies perfectly on his own. Should the original loan application be denied and start a new application from scratch, or does this qualify as a denial/counteroffer?
Where can I find a copy of the exact information/wording that is to be placed on a consumer loan application that is also used for real estate-secured requests? Using the Internet for research, much of the info seems contradictory.
When a borrower submits a request for a mortgage pre-approval (borrower intends to purchase, but has not identified a property), are we required to disclose with TIL/GFE? Also, I can not find a definition of Loan Application as determined by Reg Z. Where can I find this?
I have a loan application for a bridge loan. The customer wants to use their current residence as collateral to purchase a new residence. We will be taking a lst lien on the existing residence as well as a 1st lien on the new residence. The loan will be for 6 months, interest only. What type of disclosures do I need to prepare? Does Early TIL come into play? We will not be doing permanent financing.
Question: I have heard lots of conflicting information about the HMDA rules that take effect in 2004.
Are there any situations in which a loan application would not be required either by bank policy or regulation?
We have a loan application that was denied based on low appraised value. The proposed collateral was property that is located in a flood zone. The flood letter was sent to the customer in a timely manner, but has not been returned. Does this create a problem?
Our Consumer Lending unit received the following response to a recent audit. "According to the regulation, a bank may pull a credit report on a person if they have a permissible purpose. An application for credit is considered a permissible purpose. When the Contact Centers take applications over the telephone (he doesnt mention anything about the Internet) they are only speaking with one of the applicants, but if the application is joint, credit bureaus aer obtained for both applicants. Without talking to the joint applicant, the bank can not be sure that the second individuaal is aware of, or wants to apply for a loan. If a co-applicant does not want to be an applicant on the loan, the Bank would not have a permissible purpose for obtaining the credit bureau. It is recommended that the Consumer Lending Dept require that all parties on a loan application be made aware that a credit bureau will be obtained." I realize that this is only a recommendation, but this team believes because a compliance auditor wrote this, they need to act on this recommendation. Is there some litigation that suggests we need to do this? I simply can not find anything, anywhere that states we are required to verbally inform a co-app that we are going to pull a cbr. What am I missing here? Is this a business decision and if so, based on what? If its written somewhere, I would like to see it. What are other institutions doing?
Is it a RESPA violation for a mortgage lender to pay a % of the loan commission to the realtor if the realtor actually takes the loan application and is disclosed on the settlement statement?