Is it legally permissible to email a firm offer of credit?
If an approved borrower loses their employment just before closing, what is the process to then deny the loan?
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:
Does an incomplete application for Regulation B mean an application is not HMDA reportable?
Should a written application be required for all business purpose applications, including those for HMDA reportable transactions?
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?
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.
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.
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.
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.