What income do you use for reporting HMDA on commercial property? Should it be the gross amount or the rental income on the property?
A director of a bank has a Freddie Mac Loan and the bank is servicing the loan. Does the bank report the current balance as an insider loan on the Schedule RC-M of the Call Report?
What are the rules for reporting Consumer Loans on Land for CRA purposes? More specifically, would you use the geo info of the consumer or the land being bought or refinanced?
My bank does mainly commercial lending. We have a couple of 'refinance' scenarios that we have questions on. We had a loan approved in 2010 - the purpose was refinance business debt and my bank was taking a subordinate lien position on the principal's residence. After the bank's approval the borrower did not approve our terms and my lending officer did no further investigation so I do not know if the loan we were paying off was secured by a lien on their personal residence or not to know if it falls under HMDA. How do we make the determination as to if it is HMDA or not?
The bank is making a loan to a consumer to purchase a lot. The collateral for the loan is another lot with a dilapidated house on it, which is to be torn down. Our appraisal states that it is subject to the old house being torn down. I know the loan is subject to Reg. Z, but is it subject to RESPA?
If you have a commercial loan that is in a construction phase to construct apartments is this HMDA reportable? I assume if the loan is a construction to permanent financing then it would be HMDA reportable? I am not so sure about just a construction financing phase?
We are refinancing a customer's Commercial Mortgage with another bank. The loan will be secured by a first lien on the customer's principal residence. However, in order to obtain a first position lien on the principal residence, a portion of the proceeds of the new loan will be used to refinance the existing loan on the principal residence. Is such a loan HMDA reportable, and to what extent?
The transaction is a commercial loan to an entity. The loan is secured by a limited guarantee from a Director who has an equity interest in the entity (25%). What loan amount are you required to report/capture for Regulation O?
Currently our policy is when we have a face to face application and only the applicant is in front of the loan officer, he/she marks the face to face box and the 3 boxes,( ethnicity, rate and sex) for the person in front of him/her. It is then our policy to contact the other applicant by phone and ask the GMI questions of the person that was not in front of the loan officer. Next the loan officer is to complete the GMI for that applicant (indicating he/she does not wish to furnish the information OR completing the 3 boxes) but write on the signature line that the information was taken by phone. Is that correct? Or on these face to face applications should we be completing the GMI information for the applicant that is not in front of the loan officer based on observations such as their last name or ask the applicant that is in front of the loan officer?
Are we required to keep a copy (signed or otherwise) of the "Your Credit Score and the Price You Pay for Credit" document for mortgage or non-mortgage loans? It is produced when we produce a credit report and is given to the customer as part of the closing package.