Most Popular Lending Content
Trusts & TIL Requirements -- John M. Floyd and Associates
09/02/2003
We made a loan to two individuals using property that is their primary residence. The property is titled in the name of a Trust. The individuals signed the note as borrowers and the Mortgage as Trustees for the Trust. Our loan document program did not automatically prepare the ROR.We did prepare the ROR for the individuals. We assumed TIL fell into place as the purpose of the loan was consumer purposes, the Borrowers are natural persons, using primary residence as collateral, but titled in the Trust name. In your opinion are we in compliance? We feel that we are.
Adverse Consequences from Late Adverse Action Notices
09/02/2003
We have just discovered that one of our loan officers has turn down applications on his desk since January 2003, what would be the proper way to handle this, is there any additional information that should be included in the letter since it is past the 30 day period to send out the letter. I think he has around 7 applications, is there anyway not to have a violation from the auditors.
Maximum Late Fee for Delinquent Loans
09/02/2003
I am the internal auditor at our bank and am currently reviewing lending operations. I am seeking to determine if there are any regulations or statutes that limit or prescribe amounts that can be charged borrowers as late fees for delinquent loan payments.
OCC Preempts Georgia Law
09/01/2003
The OCC has published its conclusion that national banks are not subject to the Georgia Fair Lending Act (GFLA"). The GFLA contains strong measures designed to prevent predatory lending.
Home Equity Loans, Property Purchases, and HMDA
08/18/2003
If a customer has a loan with one loan number attached to it but within this loan he is buying and selling homes with the money he borrowed do we have to do a HMDA on each property, or just on the original loan?