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Compliance Calendar
02/01/2001
February
Compliance Calendar
02/01/2001
MarchMarch 9 is the due date for comments on the Federal Reserve Board's proposal to amend Regulation C, HMDA, to increase the information reported on the LAR.
The APR is calculating lower than the rate. Can that be right? -- e-bgroup
01/16/2001
We are currently offering a 5/1 ARM at 5.50% with caps of 2/6. Margin of 2.75 based on 1 yr t-bill. Currently the T-bill is 2.06 therefore using this as an estimate for future payment changes results in the rate lowering with the 61 st payment. This then results in a lower finance charge throughout the life of the loan and therefore calculates an APR that is lower than the rate. Is this correct? I'm not seeing other banks with similar products disclosing a similar APR.Any information you have would be greatly appreciated.
No Notice May Be Good News
01/15/2001
One year ago one of your customers disappeared leaving a large balance due on an unsecured loan. Yesterday you saw him in a local café and asked him about his debt. He laughed and said he had moved out of state and after the waiting period had run filed bankruptcy. He got his discharge last week and was moving back home. You never received notice of the bankruptcy, is the discharge effective against your loan?
Can you Rely On a Prior Flood Determination?
01/15/2001
According to the NFIA, a previous flood determination may not be reused when making a new loan. However, if it is not new (i.e., involves increasing, extending, renewing, etc.) the original flood determination can be used if it is >7 years old, etc. Also, for home equity/second mortgage loans where the lender has a first mortgage and can provide evidence that adequate flood insurance is in place, the lender can rely on the original flood determination. The NFIA does not address whether a lender can rely on a previous determination, specifically, for home equity loans where the lender has the first mortgage and the security property is not in a flood zone and no coverage is in place. My question: Can a lender rely on a previous flood determination for home equity loans, where the lender has the first position, and when the security property is not in a flood zone?