Most Popular Lending Content
Using a Portion of a Town as your CRA Assessment Area
03/24/2003
We recently opened a new branch and must add the area to our defined lending area (assessment area). We live in a rural area and deal with BNA's. Can we use the BNA #'s to define this new area or must we use a whole town? Presently our CRA policy has towns and the BNA's listed. The new area borders on a very large town with various BNA #'s. We do not really want to include the whole town because we know we can not be competitive since most of the town is over banked. We are hoping to just list the surrounding BNA's.
Preliminary disclosures: When do you start counting the days?
03/17/2003
Preliminary disclosures: When do you start counting the days? Is the day you receive the application consider day 1 or does the time begin the day after you receive the application? For example if I received a completed application on 2/18/03 do preliminary disclosures have to be given on 02/20/03 or do I have until 02/21/03?
Can we offer extensions/deferrals on open end lines of credit?
03/17/2003
Can we offer extensions/deferrals on open end lines of credit?
Documentation: Revocable Trusts & Real Estate
03/17/2003
We are beginning to see number of our customers forming revocable trusts. What documents do we need for a real estate loan secured by the primary residence of the Trustees when the title to the real estate is held in the trust name? Do RESPA and TIL apply?
What are Life of the Loan requirements for flood insurance?
03/17/2003
What are Life of the Loan requirements for flood insurance? Our understanding is that a bank must determine if a property is in a flood area and then at the time the bank has committed to make, increase, extend, or renew a loan the bank must require the proper insurance, if it has determined that the property is in a flood area. Also, the bank must monitor that this proper insurance is in place for the life of the loan. Force-placed insurance may be required if a policy lapses or the bank has knowledge of a change in flood status. Life of the loan tracking for properties which were determined not in flood areas, is not required because there is no duty on the part of the lender to monitor any changes in the flood maps or perform any type of portfolio review when flood maps are revised. Is our understanding of the flood insurance requirements correct?