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Latest Lending - Reg. C Topics

Collection Method Questions for HMDA

01/26/2020

This question has come up before but I have not seen a clear answer. If the application is NOT taken face to face, how should the collection method questions be answered for HMDA? Code 3 (NA) is only supposed to be for applications where the requirement to report the data does not apply to the covered loan. We would use code 3 on applications where it is an entity. Code 2 (not based on visual observation) would be the only choice that would make sense. What are your thoughts?

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?

Adding Co-Borrower After Closing Disclosure

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?

New Business Loan App for the New Borrower?

08/12/2018

I have an entity assuming the debt of another to purchase a residential property. Since the loan will be secured by a first lien on a residential dwelling, will I need a new business loan application for the new borrower? Our original business loan application specifies the original borrower.

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COMPLIANCE Q&A: Do we need an LEI if not reporting a ULI?

Question: We are a low volume HMDA filer that now qualifies for the new partial exemption for reportable fields.

COMPLIANCE Q&A: HMDA Loan: Reporting number of units

Question: I have a two-part question for the number of units to be reported on a HMDA covered loan.

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Reporting Revenue on Small Business LAR

10/18/2020

When reporting revenue on the small business LAR can you please clarify the following for me: We have a loan program called "Low Doc" in which financials are not used in making the credit decision based on a number of factors, however we do have the revenue information from the customer. In order that these loans are not reported as a code 3 – and not counted in our CRA totals, is it appropriate in using the business revenues that the customer provided?

State's Public Records-Record Retention

10/18/2020

We want to know if there is a vendor or website our bank can utilize to quickly retrieve public records online from various Secretary of State offices, tax cards & tax bills to pay escrowed taxes, retrieve recorded real estate docs i.e. recorded Warranty/Quitclaim Deeds, MTG-DOT and AOR's. The majority of states have their records available online but behind a paywall where you have to pay for each individual page of each document. There's 25+ of us between Lending, Legal, and Compliance that need access at our bank to these docs. In my previous banking career, we utilized a website called NETRONLINE.com with a paid subscription but it appears it is no longer available. Is there a substitute?

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