06/07/2010
Is a loan secured by a savings or CD account covered if the purpose is the financing of secondary education?
04/19/2010
A lender approved a mortgage loan and did not gross up the customer's social security income, so for HMDA reporting, I used what the loan officer came up with in determining his income. Now, upon reviewing my quarter-end HMDA reporting, the HMDA compliance officer claims the social security income needs to be grossed-up and that I should change my HMDA LAR to reflect this change. Is this correct? I thought that I was to report my HMDA according to the data used to approve the loan application. Please clarify this for me.
03/29/2010
We have a mortgage preapproval program as defined by 203.2 - a preapproval program as a request for preapproval for a home purchase loan is an application under paragraph b(1) of this section if the request is reviewed under a program in which the financial institution, after a comprehensive analysis of the creditworthiness of the applicant, issues a written commitment to the applicant valid for the designated period of time to extend a home purchase loan up to a specified amount. Section 3500.2 defines an application as the submission of a borrower's financial information in anticipation of credit decision relating to a federally related mortgage loan, which shall include the borrower's name, the borrower's monthly income, the borrower's social security number to obtain a credit report, the property address; an estimate of the value of the property, the mortgage loan amount sought, and any other info deemed necessary by the loan originator. The six items to trigger a GFE requirement are property address, loan amount, monthly income, estimated value, borrower name, and social security. Since a property address is not known on a preapproval, is a GFE required? What if we request verification of income? Does that not trigger a GFE on a preapproval even if the property address is unknown?
03/22/2010
When a consumer loan is secured only by real estate, the title to the mobile home that rests on the property is not taken as collateral. Should early disclosures be provided to the customer or can the loan be treated as if it is vacant land?
03/01/2010
Is purchasing a time share, using the person's primary residence as security, HMDA reportable?
01/25/2010
If the only term you are changing on a Commercial Revolving Line of Credit is the maturity date, can this be accomplished with just a modification agreement, or is a new note, mortgage, security agreement, etc. required?
01/25/2010
Is the federal credit application insurance disclosure required for mobile home only loans?
12/14/2009
Marketing is working on our E-SIGN promotions and wants to know what the E-SIGN agreement will include. Is it just lending, deposits, or can it include both?
11/23/2009
Relative to the question: <a href="http://www.bankersonline.com/lending/guru2009/gurus_ldng082409e.html">Flood Insurance on Bank Owned Foreclosed Property</a>. what if the bank has not foreclosed, but the property is in nonaccrual/charge off status on the books, security has not been released, the customer is still living in the home, and there are no plans to remove him?
11/02/2009
When making a CRA investment mortgage security, does the investment need to be at low or moderate area or need only to the low or moderate income individual?