07/21/2024
In reviewing our Consumer Loan Application, I noticed there is no formal Reg B section in which the Borrower(s) indicate whether they are applying for individual credit or joint credit. In my prior employment, the applications always included a formal Reg B section. Is this formal section required?
03/17/2024
Our residential mortgage lending team is very thorough to ensure that the Lending Committee signs-off on adverse action/denial documentation. We are newer to commercial lending. Thus, the Board approves all commercial loans.
The commercial lending officer has been given the discretion to decline certain requests before they even get to the Board. The question is more of a compliance/procedural one. Is it sufficient for only the commercial loan officer to sign-off on adverse actions, or should we be obtaining Board sign-off on these as well....under our current approval structure?
02/25/2024
Can you remove the primary borrower off a pending loan? I was under the impression that as long as both borrowers were married, and they both completed the application and received the initial disclosures that the primary borrower could be removed and the co-borrower moved over to the primary borrower position. This was the only way, and any other attempt would result in a denial, or withdrawn application.
We have done this with a couple of our loans, but upper management wanted documentation stating that this can be done.
12/24/2023
When sending an adverse action letter for joint applicants with different reasons for denial, can I use two letters (one for each applicant) for all denial reasons combined?
11/05/2023
There is confusion over the disclosure for the Reg B, Right to Receive Copy of Appraisal.
I read that David Dickinson (Aug 9, 2010) said there is no date requirement for this disclosure, whereas Dan Pesfull advised it is given at or within 3 days of application but can be given at closing. Per the CFPB website it must be given within 3 business day of receipt of application. (12 CFR § 1002.14(a)(2). Can some one clarify.
07/02/2023
When an applicant emails a mortgage loan application, when it is considered received by the bank? When does the disclosure clock start to run?
06/04/2023
Regarding the new small business data reporting requirement expected to come out soon. Will this "1071" requirement be similar to HMDA and CRA whereby if it’s HMDA it cannot be reported as CRA? So if it’s a HMDA reportable loan, then we won't report it for the small business data?
04/23/2023
Are there best practices for handling loans with two borrowers and then one passes awayY What is the best way to handle consumer and mortgage loans when this happens? Should the bank require the survivor to refinance or allow them to make regular payments?
And what about HELOCS? Would it be best to remove the limit and allow payments on the balance, leave limit and allow terms of HELOC to continue or require them to requalify/refinance?
Then, what about IRS reporting if the decease person's SSN is on the 1098?
11/27/2022
We receive submitted applications from our website that are considered complete per TRID. Upon receiving the submitted application, we attempt to directly contact the applicants by phone or email regarding the application and items needed to make a loan decision.
If we do not receive any contact from the applicant, what are the notification requirements? Should the app be considered incomplete and we send a Notice of Incompleteness and if there is still no response by a certain date, we can close the file? Also, what would the timing requirements be to send the notice and then to be able to close the file?
11/13/2022
I have a borrower who would like to use his primary residence as collateral for a business line of credit in the business' name. Does TRID apply or any other regulations if its a business purpose?