07/16/2007
We have a loan in a flood zone and the loan balance is $37,000.00, but there is only $16,600.00 in flood insurance. We have sent the notice about the shortage of insurance and still no additional flood insurance has been purchased. Should we force place flood insurance for the full amount of the balance or only the difference between the loan balance and the flood insurance purchased by the customer? Can we have two insurance policies on one property?
06/25/2007
If the maximum amount of flood insurance for a private home is $250,000, but the structure's value far exceeds that amount, what steps need to be taken to properly insure the loan? Additional coverage is needed, but our local insurance agent seems to not be able to explain how to get the additional coverage. He just says most of the banks he deals with go with the $250,000 regardless of the value of the structure. Please advise.
06/18/2007
Even though Part 365 of the Real Estate Lending Standards states that a 1-4 family owner occupied LTV percentage is 85%, is it acceptable to go to 90% if our loan policy discloses such?
04/30/2007
If two individuals have equal credit and other factors and one is granted a loan due to a non-bank related personal or business relationship with a bank officer, is this considered discriminatory from a fair lending/HMDA standpoint?
10/09/2006
What are the bank policies that need board approval and how frequently?
10/09/2006
When collateral property is located in a Flood Hazard Area (and a participating community) we were operating under the impression that the mandatory purchase guidelines required either a NFIP or a WYO flood insurance policy be purchased. We now have someone questioning this since standard Mobile Home Owners policies include flood insurance coverage. Is this type of insurance acceptable to meet the flood requirements? Or are we limited to either NFIP or WYO policies?
03/20/2006
I am a finance broker for several financial institutions, and have agreements in place to do business with them. We currently do financing and refinancing on chattel loans with several investors. My contract with one of the institutions states that I will not solicit any of their customers for refinancing. My question is as follows: Would it be breaking the Fair Lending or Fair credit Laws to deny someone the opportunity to refinance through my organization because they, who came to me direct, are financed with a company I do business with currently? I have a lender that is asking me to do this to my customer, and I feel like this is wrong and do not want to participate in this activity. Is this against the law? Where could I find information on this to prove to the lender that this is an improper activity, and is not treating the customer fairly and equally?
03/13/2006
It is my understanding that in the event of a flood claim only, one policy written for the same property will be honored. If it is determined that an existing Condo flood insurance policy does not have adequate coverage, is requiring the client to obtain a separate flood insurance policy on their condo unit, for the difference, unacceptable?
02/06/2006
How do you recalculate the APR on an interim construction loan, if you add additional funds during the original term? We do it as a modification and the dollar amount of the loan is the only thing that changes. Are we supposed to recalculate the APR using the original term of the note, or from the date of the modification to the original due date? If possible, we do not want to "refinance" the loan and payoff the original and do a new note due to title policies, etc.. What are our options?
01/16/2006
I've been constantly running into a "You are not in compliance" issue in the company where I started working recently. Let's say I sent the application package to my client dated 12/01/2004. The client send the signed and dated package back one month later. My processor is insisting that the client should've dated it within 3 days. Otherwise, it's not in compliance. I think it does not make sense. If I send the package by regular mail it can take 5 days to deliver it, not to mention that the client may not sign it right away, and then it will take another 5 days to get the package. Please explain this 3 days compliance thing. I don't think my processor is interpreting it correctly.