Latest Lending - Reg. C Topics

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?

Use of the Lender Information form

04/07/2019

Are we required to use the Lender Information Form?

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.?

Mandatory compliance date for the Uniform Residential Mortgage Loan Application

02/03/2019

What is the mandatory compliance date for the new uniform residential mortgage loan application?

Required use of the Uniform Residential Mortgage Loan Application

01/06/2019

Are we required to use the new 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.

Rate Spread HMDA/Reg C: Apply to Construction?

01/14/2018

Does the rate spread under HMDA Reg C apply to construction loans for residential 1-4 family?

"Correct "Purpose of Loan" for Closed-End Equity

01/15/2017

I have a HMDA question. What would be the correct "Purpose of Loan" to use for a closed-end equity loan that's not for home improvement? Appendix D doesn't tell me what I should be using.

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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.

Is email receipt of the LE sufficient

01/19/2020

We mailed the borrower’s Loan Estimate and they emailed us that it was received, and they want to proceed with the loan. Can we act on this emailed notice?

MIL - Open-end and ODP Coverage

01/19/2020

The Military Lending Act does not specify if the Act applies to an open-ended Overdraft Protection line that is tied to a checking account or a closed-ended loan secured by the applicants’ deposit accounts such as a savings and/or certificate of deposit. Does the Rule apply to both consumer credit types?

Latest Lending - Reg. C Topics

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