Most Popular Lending Content
HMDA & Multi-family Dwellings
08/18/2003
Isa 2-story townhouse building considered 1-4 family or multifamily for the purpose of HMDA?
Multiple Problems With Old Mobile Home Loans
08/18/2003
We currently have about 50 mobile home loans that will be coming due this year and next. These loans were written with under liberal terms, most are on a 15 to 20 year am, some even with 30 year am, with 5 to 7 year balloons. Because of the declining value of the mobile homes, the principal amount coming due is, in many cases, greater than the value of the collateral. Some are with land, some titled. The bank is not anxious to refinance any of these loans (and is not contractually obligated to) and plans to encourage these borrowers to refinance elsewhere, telling them we no longer make these types of loans. We will be revising our loan policy to reflect this. However, if a customer threatens to walk away from the loan, we will refinance at different terms including pricing high enough to ensure at least some principal reduction. The decision to refinance any of these will be made case by case as will the terms of the refi. We'll treat them as work-out loans. In addition to HOEPA coverage, I am concerned about possible disparate impact (probable higher percentage of minorities, families with children, single women,than the general population) and the fact this may appear to be predatory in practice (definitely not the intention). Assuming we can adequately document our "business necessity" for doing this, what is our risk in handing these mobile home loans in this manner?
Are disclosures necessary for a $1MM consumer loan?
08/18/2003
I have a lender making a $1MM loan to a consumer to construct a personal residence. The loan is NOT real estate secured. I am finding myself unwilling to accept that there are no disclosure requirements for this transaction, however, I believe it to be exempt from Reg Z,RESPA, HMDA and Flood. Is there something I am overlooking?
Home Equity Loans, Property Purchases, and HMDA
08/18/2003
If a customer has a loan with one loan number attached to it but within this loan he is buying and selling homes with the money he borrowed do we have to do a HMDA on each property, or just on the original loan?
What is the definition of "unimpaired capital"?
08/18/2003
What is the definition of "unimpaired capital"?