02/03/2019
What is the mandatory compliance date for the new uniform residential mortgage loan application?
02/03/2019
Concerning a counter offer on a consumer loan. In this case not mortgage related. To my understanding a counter offer applies when you want to change a term from the original request in order to position the borrower to grant approval. IE reduce loan amount, extend duration of term. Can a counter be used to request a co-signer /endorser to be placed on the loan.
With a comment that states this loan would be granted as long as the added co-signer or guarantor is approved?
02/03/2019
I have a question in regards to section §1002.14(a)(2) and §1002.14(a)(4) below in Reg B. Section (a)(2) below states the lender shall provide the applicant a copy of the “right to receive a copy of appraisal” disclosure within 3 business days. We have a situation where the customer withdrew their loan PRIOR to the 3rd business day. According to section (a)(4) below it ONLY references back to section (a)(1) which pertains to the actual appraisal and NOT the disclosure itself. So in instances where a loan is either withdrawn, denied or incomplete prior to the 3rd business day do we have to still send the disclosure or not?
"DISCLOSURE. For applications subject to paragraph (a)(1) of this section, a creditor shall mail or deliver to an applicant, not later than the third business day after the creditor receives an application for credit that is to be secured by a first lien on a dwelling, a notice in writing of the applicant's right to receive a copy of all written appraisals developed in connection with the application. In the case of an application for credit that is not to be secured by a first lien on a dwelling at the time of application, if the creditor later determines the credit will be secured by a first lien on a dwelling, the creditor shall mail or deliver the same notice in writing not later than the third business day after the creditor determines that the loan is to be secured by a first lien on a dwelling.
WITHDRAWN, DENIED, OR INCOMPLETE APPLICATIONS. The requirements set forth in paragraph (a)(1) of this section apply whether credit is extended or denied or if the application is incomplete or withdrawn."
01/06/2019
If an individual applies for a loan and they don't qualify, is the lender required to formally disposition (deny) the loan request? Or can they solicit other individuals to be added to the application to see if they would
help qualify and get loan approval?
01/06/2019
Are we required to use the new uniform residential mortgage loan application?
12/30/2018
Can a co-borrower be added to a loan after a closing disclosure is issued?
12/23/2018
When it comes to processing a commercial loan request that includes a 1-4 family dwelling, are there any preliminary disclosures required to be given to the customer?
12/09/2018
If an early Closing Disclosure has been issued and the borrower now wants to add a co-borrower, what are the compliance issues that need to be reviewed?
Under Reg Z, is there a new 7 day waiting period to close due to a 'new' application' with the co borrower?
Do we go off of the date of application of the 'co borrower' or the original primary borrower application?
This is not technically a changed circumstance, but if no fees are increased that break tolerances, nor a program change, is there an issue?
12/02/2018
We currently offer a loan, repayable in six monthly installments at zero percent interest, to help customers bring their checking account to a positive balance.
Letters are automatically generated and mailed to customers who may qualify for such loan once their account becomes 30 days overdrawn for $100 or more.
Upon receipt of the notification, the customer must call in as directed in the notification (or they can come into the branch) to request the fresh start loan. Their account will be reviewed. If the customer has previously had a fresh start loan with us, we will not make them another fresh start loan. In those situations where a customer requests a fresh start loan and we
are unable to make them one, would we owe the customer a Notice of Action Taken? Would Regulation B apply to these fresh start loans?
12/02/2018
Bank policy is to require any principal of the business with 20% or more interest to guarantee a loan. If you have a 5% interest owner decide to guarantee the loan which is not a requirement of the Bank, would a joint intent as the guarantor confirmation be required, or is that only if they are not a principal of the business?
