Our bank has made a loan to a corporation that owns and operates mobile home parks. The purpose of the loan is to refinance one park with 150 pads. Some of the homes in the park are owned by the corporation and rented out to individuals, and some pads are rented to individuals that own their own mobile homes. Is this a CRA small business loan or a multifamily HMDA refinance loan?
To what extend does Reg B apply to an automated small business credit scoring program (eg. notice, adverse action, etc).
The U.S. Department of Justice is working hard at fair lending enforcement. This is not a concern that has faded into the background. Quite the opposite is true.
CRA Question: The action date should be the note date, correct? We are booking commercial loans with the "funding date" as the original date on the system, not the note date. Shouldn't the loan processing department use the "actual" note date as the original date?
With the Federal Reserve's most recent attempt to clarify the signature rules of Regulation B, the debates about compliance and proof of compliance are running rampant.
Banks' marketing budgets have been steadily rising over the last several years as they scramble to keep up with competition from other financial and non-financial firms, a survey by American Banker
If a 2004 commercial loan is secured by residential real estate either as primary or secondary collateral is it HMDA and CRA reportable?
Is the retention period for denied loans two years?
Adverse Action Notices -
Time for a Refresher
Is it acceptable to use community property income to qualify an applicant if the applicant is applying for separate credit? Our applicant (Mrs. X) works for her husband's business and is requesting a $100M unsecured line of credit for herself and a small business she operates. Her husband, who earns the majority of income of the household, is not a co-borrower or co-signer. Based on Mrs. X salary' alone she would not qualify for this loan under our underwriting requirements. But, if we use the combined income of Mr. and Mrs. X and use their combined annual expenses (included the proposed loan), she would qualify. The argument is community property income can be used to qualify an applicant because she lives in a community property state (California).