Most Popular Lending Content
ARM Disclosures by a Broker
01/03/2005
We are a state-chartered FDIC-insured bank that originates residential loans. We do this through a correspondent (we close/fund loans and sell to correspondent) channel, as well as act as a broker on loans for wholesale lenders. In the broker capacity we would be referred to as a TPO "third party originator." With regard to ARM program disclosures, are we required to give these when originating brokered loans or only when we are the "creditor" and closing loans with our own funds via correspondent channel?
Proving Early Disclosures Were Made
01/03/2005
How do we document in our files that we have sent out Early TIL disclosures on a timely basis? We keep a copy of the Early TIL in the file, but it is not signed by the customer in some cases (if the lender mails them rather than giving them to the customer at the time of a face-to-face application). I am told by our lenders that borrowers don't always return a signed copy of the Early TIL, so that can't always be relied upon for proof. Any suggestions?
The Ins and Outs of Credit Scoring
01/01/2005
It is talked about in many contexts. It is a term tossed about without clear definition. It engenders fear and caution among lenders. It raises compliance concerns.
GFE Requirements
01/01/2005
Question: We originate investor mortgages on 1-4 unit owner occupied properties. One of our investors is asking for a Good Faith Estimate within 3 days of the Credit Report.
Information Security: FTC Action
01/01/2005
Banks and thrifts are not alone when it comes to requirements to maintain security for customer information.