Most Popular Lending Content
Advertising, IRS tax forms, Privacy, RESPA
02/25/2024
Our marketing department brought up the idea of handing out $50 coupons to our customers to entice them to refer folks to get a mortgage loan with the bank. The idea is that if a customer refers someone for a mortgage loan and it closes, the customer can redeem the $50 coupon for cash. I reviewed 1026.36 but it only seems to cover MLO compensation. RESPA's 1024.14(b) seems most applicable but i'm not sure if that just pertains to the parties involved in the transaction. This would be a referral for our customer who told someone to get a mortgage with us. Are there any regulations on a $50 referral ‘bonus/compensation’ to our customer for referring someone to one of our MLO’s to close a mortgage? It seems similar to what the big banks do with something like a $200 bonus to open an account with them.
MLA Checks on All New Loans
02/18/2024
I'm new to the compliance world and brand new to this institution. I just received an external audit from a consulting firm that cited multiple MLA findings for obtaining applicant's MLA status for an exempt transaction (vehicle purchases). Our credit reports include the MLA check automatically. Are those legitimate findings? Do we need to turn off the MLA check that's part of the credit report?
When to and Not to Verify MLA Status
02/18/2024
How often does active duty have to be checked to comply with MLA? If we have originally checked the active duty status on an origination and we need to renew the loan, should we check that status again?
Resolving exceptions
02/18/2024
What is involved with “resolving” an exception?
Bank president signs on a non-profit account that just became overdrawn. Does Reg O apply?
02/18/2024
Our bank president is a signer on a local non-profit’s checking account. That non-profit just bounced a check – does Reg O come into play here? Can we pay the OD and waive the fee?