Latest Lending - Reg. B Topics

"XYZ Data" on Adverse Action Notice

08/25/2019

I have a client (a lender) who orders their credit reports from "XYZ Data" and when a loan is declined, they list Equifax on their Adverse Action Notice (with appropriate address and phone number) and they have now been told that because "XYZ Data" is considered a reseller of credit under the FCRA 603(u) that they should also list XYZ Data (along with its name and telephone number) on the Adverse Action Notice. Is this true?

Regulatory Disclosure for Refi Commercial Mortgage

08/04/2019

What regulatory disclosure is required for refinancing a commercial mortgage loan?

Treating Customer Fairly During Debt Collection

07/07/2019

I know Reg B talks about a lender not discriminating when collecting on a debt. What other regulation talks about a lender fairly treating a customer during collection procedures? Fair Debt Collection Practices Act? I think a lender collecting their own debt is exempt as a "debt collector" definition.

Denied Due to Collateral & Adverse Action Notice

06/30/2019

If a loan is denied due to collateral value, would the adverse action notice include that an outside source was used in the decision and the outside source was the appraiser? I believe the appraiser would NOT be an outside source for this purpose.

Aggregated and Disaggregated Data

04/28/2019

If an applicant chooses not to provide the borrower demographic data do we still collect it based on visual observation and surname?

Additional Borrowers

04/21/2019

How many borrowers can apply using a single Uniform Residential Mortgage Loan Application?

Modifications Construction Perm-Reduce Rate

04/14/2019

I have a question about modifications on our construction perm loans to reduce the rate to sell on the secondary market. We have our construction perms, that after completion and when the loan is closed out, that upon completion of the construction, a “float-down” of the interest rate may be allowed if it meets the guidelines to sell on the secondary market. Does this trigger anything for Reg B or Adverse Action?

Use of the Lender Information form

04/07/2019

Are we required to use the Lender Information Form?

Appraisal Notice On New Request?

04/07/2019

Do we need to send an Appraisal Notice on a new request if we are using an existing appraisal we already have for a separate loan?

Use of the old four-page uniform application with the demographic information addendum

03/03/2019

Can we continue to use the old four-page uniform application with the demographic information addendum or must we convert to the new eight-page form.?