Our financial institution is not a bank or credit union and is regulated by the state. We do not see a choice to enter our regulator on the HMDA LAR. What do we do?
Concerning a counter offer on a consumer loan. In this case not mortgage related. To my understanding a counter offer applies when you want to change a term from the original request in order to position the borrower to grant approval. IE reduce loan amount, extend duration of term. Can a counter be used to request a co-signer /endorser to be placed on the loan. With a comment that states this loan would be granted as long as the added co-signer or guarantor is approved?
I have a question in regards to section §1002.14(a)(2) and §1002.14(a)(4) below in Reg B. Section (a)(2) below states the lender shall provide the applicant a copy of the “right to receive a copy of appraisal” disclosure within 3 business days. We have a situation where the customer withdrew their loan PRIOR to the 3rd business day. According to section (a)(4) below it ONLY references back to section (a)(1) which pertains to the actual appraisal and NOT the disclosure itself. So in instances where a loan is either withdrawn, denied or incomplete prior to the 3rd business day do we have to still send the disclosure or not? "DISCLOSURE. For applications subject to paragraph (a)(1) of this section, a creditor shall mail or deliver to an applicant, not later than the third business day after the creditor receives an application for credit that is to be secured by a first lien on a dwelling, a notice in writing of the applicant's right to receive a copy of all written appraisals developed in connection with the application. In the case of an application for credit that is not to be secured by a first lien on a dwelling at the time of application, if the creditor later determines the credit will be secured by a first lien on a dwelling, the creditor shall mail or deliver the same notice in writing not later than the third business day after the creditor determines that the loan is to be secured by a first lien on a dwelling. WITHDRAWN, DENIED, OR INCOMPLETE APPLICATIONS. The requirements set forth in paragraph (a)(1) of this section apply whether credit is extended or denied or if the application is incomplete or withdrawn."
What is the mandatory compliance date for the new uniform residential mortgage loan application?
On a consumer real estate ARM loan, the loan just adjusted. The officer is requesting to modify the loan and change the index, margin, and adjustment period. The request is primarily due to competitive reasons. Can we change the index, margin, and adjustment period without having to do disclosures?