What open-end lines are counted for the HELOC threshold?
As to a loans HOEPA status, are second homes and vacation homes considered not applicable for HOEPA which would make the status code 3 on the HMDA LAR report?
Is there a difference in reporting the total units for two single family homes vs a duplex where both units secure the loan but are contained in the same “property”? Sometimes the duplex will have separate deeds for the units, other times it is on one deed if there is one owner.
Scenario- A customer receives foreign wires for "family support." This customer also received an unsecured loan for a purpose of "family support". The customer withdrawals most of the account funds at casinos in cash and then makes cash deposits after winning money. The lender doesn't have a concern on the loan side. What is your opinion on filing a SAR?
I have a loan on a condo unit which had hurricane damage. Because of the damage, all of the units have been demolished and it is in the process of being rebuilt on stilts. The property is in the Florida Keys and is in flood zone AE. Normally I would require proof of flood insurance once the slab has been poured, but all of the units are being rebuilt on stilts. No slabs will be poured, instead concrete pillars will be going in the ground. At what point do I need to ensure that there is flood insurance and that I have sufficient coverage? I assume if the condo does not purchase coverage I will have to force place?