Most Popular Lending Content
Internet Lending Compliance Issues
05/15/2006
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?
Do We Need to Re-disclose?
05/15/2006
When we provide disclosure statements which state that finance charges were included in the proceeds, and the customer decides to pay them up front, do we need to re-disclose? This is on a variable rate construction loan to build a primary residence.
Do We Need Early Disclosures?
05/15/2006
We are refinancing a loan for an existing customer. The purpose of the loan is construction of a house, with the collateral being the customer's principal dwelling. It is a junior lien and is being taken for abundance of caution only. I know we need to pull a flood, I think we need ROR, but we still aren't sure if we need early disclosures.
Consumer Swing Loans Subject to HMDA Reporting
05/15/2006
Are consumer swing loans (180 days or less) subject to HMDA reporting when the lender will NOT be providing the ultimate permanent mortgage?
Commercial Purpose Loan Made to an Individual
05/15/2006
If I have a loan made to an individual for commercial purposes and the loan is HMDA reportable, is it necessary to calculate the rate spread? I would think that if the loan is for commercial purposes it would not be subject to Reg Z.