Most Popular Lending Content
Reg O Preapproval by Majority of Board
06/23/2019
I have a question on Reg O, specifically the preapproval by the majority of the entire board of directors requirement under 215.4. 1. If the board of Directors authorizes a sub-committee to act on behalf of the entire board, would pre-approval by that sub-committee satisfy the regulatory requirement regarding approval by a majority of the entire Board of Directors? 2. What if the majority of that sub-committee was composed of senior management, the remaining minority members were board members and the total number of board members on the committee did not constitute a majority of the entire board?
Converting Fixed Mortgage to ARM-Refi?
06/23/2019
Can a 30 year fixed mortgage be converted to a 5/1 ARM mortgage? What information needs to be provided to the consumer to have this done and can it be a modification or must it be a refinance?
Loan w/ Temporary Financing & LE for Permanent
06/23/2019
The bank provided a construction loan to a borrower to build a dwelling. Along with the temporary financing the bank also provided a loan estimate for a permanent loan. This was done to make sure the borrower had all the pertinent information to make a decision about the new construction as well as due diligence by the bank to be certain the borrower will qualify for the end mortgage. Is it considered a HMDA reportable transaction as a withdrawn application if the bank provided the loan estimate for permanent financing? The construction loan was taken out by a permanent mortgage in the secondary market loan and not the in-house mortgage that the loan estimate referred to.
TRID Rule Apply if Borrower is Occupant/Not Owner?
06/23/2019
Does the TRID rule apply to a loan where the borrower is the occupant of the house but not the owner, or is it exempt because it's not owner-occupied?
Charge Late Fee on a Consumer Single Pay Note?
06/23/2019
Can you charge a late fee on a consumer single pay note?
