Most Popular Lending Content
Loans & OFAC Hits
10/28/2002
Under OFAC, if our loan officers are checking loan applicants for OFAC hits, and find one, are we required to decline the loan at that point? If so, what are the procedures we should follow? I find very little about lending with respect to this particular law. If we decline the loan in this case, how do we word the decline, and would it be included on the AA notice or done separately?
Credit Memorandums - Write or Wrong
10/28/2002
by Regional Examiner K. Paul Qualls, Oklahoma State Banking Department
HOEPA Benchmarks
10/28/2002
We are still struggling with HOEPA. None of us wants to originate HOEPA loans but if we do, we have the disclosures ready to issue the borrower (3 days prior). Is anyone aware of how many or what percentage of a bank's portfolio can be identified as HOEPA loans before the bank is viewed unfavorably by the regulators and/or Community Groups? Has a benchmark been published or discussed somewhere? Any ideas?
Confusion Over The New TIL For High Cost Mortgages
10/28/2002
There seems to be some confusion regarding the new TIL for High Cost Mtges that go in effect in Oct. Is this new ruling geared towards Primary residents only, or does include investment properties and if so, where can I find the verbage that states just that. I am in the state of Florida.
Pre-nuptial Agreements, Real Estate, and Mortgage Loan Signatures
10/21/2002
I have a husband and wife that signed a pre-nuptial agreement keeping real estate prior to marriage separate. The husband wants to borrow on his real estate which is in his name only. Does the wife have to sign the mortgage for his loan on his property owned prior to marriage when there is a pre-nuptial in place and can we request a copy of the pre-nuptial?