Most Popular Lending Content
Reg B - Lending to Persons with Disabilities
05/29/2006
I am on the board of a non-profit housing program. During our family selection process we ask if they or any dependents have a disability. According to Reg B section 202.8 we are allowed to do that if it is part of the selection process (we receive monies from the Lions who require it to be used for a person with a disability) but we also provide housing for those who are not disabled. Would it be prudent to have two separate application processes? One for those who would like to apply for the house using Lions money which requires a disability and one that is open to others without regard to disabilities? If you were wondering, yes, we are subject to Reg B because we carry the mortgages on the home, hence we provide credit.
Freezing the HELOC Account
05/29/2006
When a third party requests a payoff on a home equity line of credit, can we freeze the account to prevent further advances and still be in compliance with Reg Z?
Primary Residence Secured by a Commercial Property
05/29/2006
We have a customer that wants to borrower money using a commercial piece of property (a motel) to buy an existing dwelling that will be their primary residence. Even though the loan is secured by a business this is now a consumer purpose loan. Would any disclosures be required other than TIL on the note at closing?
Is Direct Marketing to Seniors an ECOA Violation?
05/29/2006
Would direct marketing to seniors for reverse mortgages be in violation of ECOA due to advertising to a particular group of people, in this case, age-related?
Outside Vendor Paying for Customer Referrals
05/22/2006
We refer customers to an outside vendor for Merchant Services. The company we deal with has created an incentive program for these referrals. They have submitted one of our employees a check in the amount of $50 for a referral that resulted in a sale. I have read and understand the RESPA implications in regards to referrals in the mortgage lending area, but what about the Deposit side of the bank? Do we allow the employee to accept the check?