Most Popular Lending Content
Affiliated Business Arrangement
02/01/2005
Question: I need some guidance on an affiliated business arrangement. We have an employee who is a SVP and Chief Credit Officer and is also over our Mortgage Lending Department.
Privacy of Information Shared with Affiliate
02/01/2005
Question: Our consumer lending center sometimes takes calls from consumers who want to apply for a mortgage loan.
FACT Act: FTC Issues Final Rule on Prescreening Notices
02/01/2005
A provision in the FACT Act requires notices to recipients of offers of credit that were prescreened using the consumer's credit report.
BSA Training Is For Everyone!
01/31/2005
I'm the Internal Auditor of a community bank and will really appreciate your help with this. I'm working on the BSA Internal Audit and was trying to see if the FDIC/State requires for all employees to complete their BSA training, regardless of their department? We have a very good compliance program and training but it seems that some of the Loan department has not finish or even started with their online BSA training. Should I include as a recommendation to make sure that all employees complete their BSA training or should I write it up as violation? If you advise me to write it as a violation, give me good arguments because I have a stubborn Compliance Officer. Once again I would like to thank you for your time and assistance.
Rescission and Home Equity Lines
01/17/2005
If the HELOC is closed simultaneously with the purchase money mortgage and the HELOC is fully funded at that time, my understanding is that it would not be subject to rescission. However, if a payment is paid on the line and later another advance is taken, is that next advance rescindable? Can the notice be given to the borrower at closing for future advances? Should specific language be in the disclosure noting that rescission does not relate to the initial advance?