90% of our loan originations (TPO and retail) are submitted with credit, contracts/appraisals, verbals, bank statements, etc. and are conditionally approved for items backing up the credit docs and sometimes appraisal; is this considered a pre-approval?
The financial regulatory agencies have issued joint guidance on nontraditional mortgage products.
Failures in lending compliance can cost as much as $14,000,000. That's the amount one lender will have to pay for unfair lending practices and compliance failures.
Does a co-signer get a copy of GFE and are they listed on the HUD1 as a borrower? Do all borrowers have to sign the HUD1?
The question has been raised whether we should keep credit reports for employees who have loans with our bank in a separate file not accessible to note department personnel. We keep credit reports used for annual employment screening purposes in a separate file accessible only to senior bank management. However, credit reports obtained for purposes of a loan to an employee are kept in the customer (employee) credit file as with any other customer. Are we violating the employee's privacy with this practice?
On our VISA statements we show "Late Fee Due" then reflect a running total of all debited late fees. i.e. if late fee is $16.00 and customer has three due we show $48.00. Our internal auditor claims we need to show the late fee in the transaction history if a total is used. Oue vendor states that Section 226.7 allows the total of like charges is acceptable. What is the proper way to disclose?
Question: I know that we have to provide copies of a full appraisal, but what if we only use a tax appraisal?
As a credit union, we do indirect loans with dealers. The belief is that it's regulation that we send members with indirect loans a statement at least quarterly. The question is: is there a regulation requiring us to send them statements or could we eliminate this?
Are periodic monthly statements required on any open end consumer line of credit regardless of collateral?
We are currently in the process of starting a loan servicing/credit administration division in our $237 million dollar community bank. What are the major issues that we need to ensure are covered? Our division is going to handle everything related to a loan in the post-closing stage to payoff.