Vendor Guru Q&A - Lending

Latest Lending - Predatory Lending Topics

Proposed Limitations on Terms of Credit to Service Members and Dependents

04/10/2007

by Mary Beth Guard and John Burnett

10% Fee on Every Draw from a HELOC

10/30/2006

If a lender has disclosed that they will charge a 10% fee on every draw made from a HELOC, can the 10% be subtracted from the actual draw amount (only 90% given to borrower, 10% forwarded to lender as fee payment) or does the 10% have to be opened as a separate receivable?

Not So Fair Lending?

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?

Nontraditional Mortgage Products: New Guidance

01/01/2006

The financial regulatory agencies have issued joint guidance on nontraditional mortgage products.

Managing Pricing

01/01/2006

At PCi's 2005 CRA Colloquium, there was much discussion on pricing in the context of fairness and predatory lending. The regulators' position was clear.

Lending Practices: Fair and Unfair

12/01/2005

Failures in lending compliance can cost as much as $14,000,000. That's the amount one lender will have to pay for unfair lending practices and compliance failures.

Updating Loan Policy to Reflect FACTA Changes

11/07/2005

I am in the process of updating my loan policy to reflect recent changes to FACTA and predatory lending. I was going to just add a general statement to the policy stating that we comply with the changes in the FACT Act. Should I elaborate more in my policy and do I need to outline the entire Act in my procedures? What recent changes that I may have missed that need to be added to adjusted to my policy?

Likely Compliance Issues

10/01/2005

Release of the HMDA data puts fair lending and CRA front and center.

HMDA: Using HMDA Data

10/01/2005

The 2004 HMDA data is finally out and the numbers show what we expected and feared: Black Americans fare less well in the mortgage market than non-Hispanic whites. Now what?

Source of Appraisals and Reg B

10/01/2005

Question: I know that we have to provide copies of a full appraisal, but what if we only use a tax appraisal?

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Appraisal Requirements and Higher-Priced Mortgage Loans

Many things went wrong in the mortgage lending process before the meltdown. Among the contributing causes were inflated property values and inaccurate property valuations.

Why Are We Confused?

If you are feeling confused, you are in good company. Almost anyone who deals with mortgage lending compliance is struggling with the changes. Questions are flying. We are surrounded by chaos.

Best Practice for Saving Emails into Document Management System

10/25/2020

What’s the best way to collect and organize important emails in our document management system?

Escrows, more than dirt

10/25/2020

While auditing a mobile home loan I saw escrow statements. Isn’t this unnecessary since RESPA doesn’t apply when we don’t have real estate as our loan collateral?

Reg B and Small Business Lending

10/25/2020

I am looking to find what aspects of Reg B are applicable to small business lending. I am creating a line by line assessment and am curious if something like this exists.

Scanning Before Closing a Commercial Loan

10/18/2020

Why should we consider scanning documents before closing a commercial loan?

Reporting Revenue on Small Business LAR

10/18/2020

When reporting revenue on the small business LAR can you please clarify the following for me: We have a loan program called "Low Doc" in which financials are not used in making the credit decision based on a number of factors, however we do have the revenue information from the customer. In order that these loans are not reported as a code 3 – and not counted in our CRA totals, is it appropriate in using the business revenues that the customer provided?

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