Most Popular Lending Content
Disparate impact
11/03/2019
Disparate treatment is still illegal but didn't the Supreme Court overrule disparate impact cases?
Notice of Incompleteness- Information Request
11/03/2019
Our commercial applicant submitted an application and we issued a (expression of interest) EOI / Term sheet. The loan officer is in communication with them and is asking for items we require to underwrite the loan. It is taking more than 60 days to receive all the items. They are coming in piece by piece. When are we required to send a notice of incompleteness? I was understanding that an NOIA would not be required since the application is still not complete and we are working with the applicant, but others are saying it should be sent now.
Property Value and LTV – Abundance of Caution
11/03/2019
What do we report for property value and loan to value if two properties secure the loan, but one was taken in an abundance of caution (AOC) and treated as AOC for the appraisal requirements?
Open-end for HMDA – more than HELOCs
11/03/2019
What open-end lines are counted for the HELOC threshold?
Code 3 on HMDA LAR Report (HOEPA)
11/03/2019
As to a loans HOEPA status, are second homes and vacation homes considered not applicable for HOEPA which would make the status code 3 on the HMDA LAR report?
