Latest Lending - Reg. B Topics

Borrower Loses Employment-Deny Loan

07/04/2021

If an approved borrower loses their employment just before closing, what is the process to then deny the loan?

Using TRID application definition for HMDA

03/28/2021

My financial institution has decided to use the 6 items that mandate TRID disclosures to trigger an application for HMDA. Is this an acceptable definition:

Reg B incomplete application and HMDA

03/21/2021

Does an incomplete application for Regulation B mean an application is not HMDA reportable?

Getting HMDA information on business loans

03/14/2021

Should a written application be required for all business purpose applications, including those for HMDA reportable transactions?

Getting all the HMDA info in the app

03/07/2021

A loan officer took an application for a dwelling secured but failed to ask what type of dwelling (site built, manufactured home, etc. Can we report NA for that field?

Does ECOA Apply to Interim Construction?

11/01/2020

We have made a loan to a builder to construct a spec home. Does ECOA apply? The same builder also has a contract build; does ECOA apply to that? We structured both of these as interim construction because both will be refinanced once the homes are complete. Neither will be our borrowers as these are investment properties.

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.

Notice Date and Letter Date for Denial

09/20/2020

It is my understanding that we have 30 days to notify the customer of our loan decision when denying the request. My question is, does the letter date have to reflect the same date of denial? I had a loan officer deny a mortgage loan within three days of application to avoid early disclosure requirements, but then the application was re-activated and the lender made a second decision with a later date. This second decision date makes the denial notice reflect more than three days from the application date. Any advice?

Home Equity Application-3 Business Days Rule

08/30/2020

If a home equity loan application is not decisioned within 3 business days and preliminary disclosures are not sent out within those 3 business days, does the application need to be canceled and a new application keyed in? That is our current practice and it's a nightmare for HMDA monitoring submissions.

Adverse Action Notices When Extension is Denied?

05/24/2020

Is a large bank required to send adverse action notices when a payment due date change or extension is denied for consumer loan products?