Most Popular Lending Content
Counteroffers and Denials on Dealer Apps
01/05/2004
Counteroffers and the need for a denial, as concerns dealer applications, have us in a quandary and we're getting differing opinions from regulators. The question is: if we counteroffer (through the dealer) and then another financial instituion ultimately makes the loan, do we need to send the counteroffer/denial to that applicant? Section 202.9(g) states: When an application is made on behalf of an applicant to more than one creditor and the applicant expressly accepts or uses credit by one of the creditors, notification of action taken by any of the others is not required. That begs another question - what if you deny and other bank approves?
Can We Take A Qualified Annuity As Collateral? -- John M. Floyd & Associates
01/05/2004
Can a qualified annuity be used for collateral on a loan?
Early TIL Disclosures on Refinance
01/05/2004
It appears it is not necessary to do the Early TIL disclosures on a 1-4 family residential refinance even with new money, but only at closing. I know Early TIL disclosures are required on Purchase and with permanent lender on construction loans. Is this correct?
UCC Filing Required on Mobile Home Loan? -- John M. Floyd & Associates
01/05/2004
Our loan software automatically "requires" a UCC filing when we take a mobile home as collateral. Is this required even if the mobile home has a title and we perfect our lien on the title?
Lien Status Reporting Under HMDA
01/05/2004
The HMDA Final Rules state that beginning in 2004 we will be required to report the lien status of applications and loans. In reviewing Appendix A to Part 203 -- Form and Instructions for Completion of HMDA Loan/Application Register [Effective as of January 1, 2004] I do not find a column on the new LAR for reporting the lien status, nor any instructions for reporting the lien status. Will this reporting information be added to the Loan/Application Register in the new FFIEC software?