Our commercial applicant submitted an application and we issued a (expression of interest) EOI / Term sheet. The loan officer is in communication with them and is asking for items we require to underwrite the loan. It is taking more than 60 days to receive all the items. They are coming in piece by piece. When are we required to send a notice of incompleteness? I was understanding that an NOIA would not be required since the application is still not complete and we are working with the applicant, but others are saying it should be sent now.
What do we report for property value and loan to value if two properties secure the loan, but one was taken in an abundance of caution (AOC) and treated as AOC for the appraisal requirements?
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.
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?
Redlining is an illegal practice under Fair Lending. Isn't it also illegal under the Community Reinvestment Act?