Most Popular Lending Content
Who Should Certify HMDA Data
05/17/2004
HMDA requires an officer of a financial institution to certify the accuracy of the data. The regulation is silent on which officer should certify the accuracy. I believe this responsibility should reside with the Compliance Officer, not Internal Audit. Do you know of any announcements, etc., regarding this, or are you aware of what the "norm" is at other financial institutions?
Usury Due to Fees
05/17/2004
I know that in consumer loans the maximum rate that can be assessed is 18% in many states. My question is, could the APR be more than 18%? We have a specific case where the rate is 15.50% and the APR is 18.285% (there is a fee of $50.00 being financed). Is this a violation?
Changing the Escrow Calendar
05/17/2004
We want to change our escrow computation year to be more in line with the date taxes are due. What is involved? From what I read, it seems to indicate that we can file a short-year statement within sixty days after the start of the new computation year and then just adopt the new computation year. Is there something I am missing? Is there any best practice on how to structure an escrow year/cycle?
Timing of CHARM Disclosure
05/17/2004
We have been sending the Consumer Handbook on Adjustable-Rate Mortgages within 3 days of application. Is that okay, or should the applicant receive it from the loan officer at application time?
Flood Cert. on a Mobile Home
05/17/2004
Is it correct that a flood certification is needed for a mobile home that is on a permanent foundation or tied down and is being held as collateral?