We qualify loan applicants based on gross income. Our credit officer says that tax free income from SSI or VA Disability is the gross income and shouldn't be grossed up. I say the income is net and should be. Who's right? If we don't gross tax SSI up, are we discriminating?
When the new calculations for flood insurance went into effect in Sept, 2009, did that regulation require that lenders recalculate each existing loan in a flood zone?
We have several loan production offices. They don't have cash drawers, are not listed as branches, and they don't service the deposit customer walking in off the street. Do we need signage such as the FDIC stickers? What if a courier for the bank picks up some proof work where only our employees make deposits instead of running to a branch?
Can you define the role of the lending compliance officer? Is it the lending compliance officer’s responsibility to see that internal lending policies are being followed and should they be responsible for keeping the policy updated?
Is an "All Risk" policy one that covers hazard and flood acceptable for flood insurance?
Can LTV be calculated using either loan amount to appraisal or loan amount to sales price? If so, are you allowed to use either intermittently, or should the LTV be calculated the same way consistently?
In researching a blanket insurance policy, it says it covers everything under the property. Does that include Flood Insurance or is a separate rider required?
What does the term "flood insurance" permanently affixed to real estate mean as it pertains to mobile homes needing flood insurance? If the bank took on the mobile home as collateral, and the mobile home that still has the tongue attached is not considered to be permanently affixed, does the mobile home not require flood insurance? Clarification is needed as to what constitutes that a mobile home has been permanently affixed versus not permanently affixed and/or anchored to a foundation.
Regarding flood insurance and the 45 day notification/waiting period before you can force place it; what happens if during that 45 day period the property floods? Is the bank just out of luck? Also, what is the logic in having to wait 45 days?
In regards to flood insurance policies about to expire that were force placed by the lender, guidance was published in 1995 to address notification procedures for MPPP policies used for force placement requiring 45-day notification prior to the expiration date of the policy. Does the 45-day notification prior to expiration also apply if the lender secured a SFIP through a WYO insurer?