Most Popular Lending Content
HMDA filing compliance involving an acquired branch
08/04/2024
We are currently in the process of acquiring a branch of another financial institution. I am by no means a guru in HMDA but certainly not in acquisitions and this is the first time we've done this in a long time (before my time). I am under the impression aftery some reading of the HMDA Getting It Right Guide, that we have to report the loans we obtain through the purchase. This is okay, but I have others saying that we only have to report the ones they originated in 2024, which I don't think is accurate, but I could be wrong. Additionally, the other institution's staff members aren't being very forth coming with information and have advised that we will get the information for the files we are getting, however, we will have to go through it to gather the HMDA required data, as they will not provide us with a LAR. I'm also trying to decipher the guide and if we qualify to not report certain fields, like Loan Costs, Origination Fees and Discount Points.
Commercial Revolving Line of Credit
07/28/2024
This concerns a commercial revolving line of credit that is secured by the borrowers' home. This loan is done in the individuals' names and the purpose of the loan is to purchase, renovate and sell investment houses. The thing that is confusing me is that they aren't making purchases or renovating with the line right now. Would this loan still be HMDAreportable since it is secured by the borrowers' primary residence?
Reducing paper, keeping auditors happy
07/28/2024
Why might auditors prefer accessing digital loan files instead of paper?
OK to increase a fixed rate with a Modification agreement only?
07/28/2024
Can a fixed interest rate be increased with only a modification agreement? Or is a new note with new disclosures required since the rate is not being reduced?
Intent to apply for joint credit
07/21/2024
In reviewing our Consumer Loan Application, I noticed there is no formal Reg B section in which the Borrower(s) indicate whether they are applying for individual credit or joint credit. In my prior employment, the applications always included a formal Reg B section. Is this formal section required?