A question has come up after we prepared a Note for a commercial loan. It was dated July 15,, but the customer did not return these documents until July 22. We funded this loan and effective dated our loan to the 15th to match the Note. Now management is saying we should not have effective dated the loan, only the date we actually funded it. Can we do this, not just for commercial but also residential loans? What is the correct way to handle loan docs returned after the Note date?
While auditing a mobile home loan I saw escrow statements. Isn’t this unnecessary since RESPA doesn’t apply when we don’t have real estate as our loan collateral?
Can a flood civil money penalty cost six figures or more?
Given all other HMDA reporting criteria being met, would a bungalow colony be considered HMDA reportable?
For banks that provide combined ECOA-FCRA disclosures, is it standard practice to “Check the 1st Box” and provide FCRA credit score information if the decline reason is not based on the consumer report, but some other factor? (i.e. insufficient collateral, product not offered, out of lending area) Do other banks do this? We understand that we do NOT have to “Check the 1st box” and provide credit score information if it was NOT used in making the adverse decision, but what would be the risk to provide this information in the above cases?