When renewing an existing RLOC and adding new money, do you need to payoff
the existing line and give it a new loan number since you are increasing the
loan amount or can you use the same loan number and renew and increase the
existing RLOC using the same loan number?
What document is used to disclose the 12-day cooling off for a home improvement loan for a dwelling in Texas?
Can a lender charge a customer for the cost of a soft credit pull prior to an application for example for a prequal or preapproval? I have heard that
there are no federal prohibitions on doing this, but I would like to have more than one perspective please.
Should the financial institution count all transactions on its HMDA LAR for the 2 preceding calendar years to determine if it is no longer required to report for HMDA?
If we have the customer sign-in to internet banking before submitting email requests such as address changes to a central location - Do we still need to implement E-Sign?
Do the restrictions on loans to executive officers apply to PPP loans?
With the new $400,000 threshold increase for 1-4 family evaluations, we have decided to pursue writing them internally to remain competitive in our market. Can we do evaluations on proposed dwellings for our builder clients?
What exception categories should an automated system track?
Scenario: In California - a community property state - assume a couple files for divorce but it is not finalized yet. The husband needs a place to live and applies individually for an FHA loan, leaving the estranged wife as a non-applicant, non-borrower, who plans on using non-marital separate funds to purchase her home.
Since this is an FHA loan, the lender needs to pull a credit on the estranged wife to count her debts towards the husband's since the divorce is not final. When the lender calls the estranged wife for consent to pull her report as per our risk management policy, she denies consent for her report just to keep the husband from getting his own place. This makes it harder for him to claim joint custody of the kids.
Reg B has contradicting situations: permissible purpose is granted for community property states so lender does not need spouse's consent. However it also states there is no permissible purpose to obtain a consumer report on a .... nonapplicant spouse who has legally separated or otherwise indicated an intent to legally disassociate with the marriage.
Can lender pull the non-applicant non-borrowing spouse's credit report without her consent due to being in a community property state, or would the divorce show intent to legally disassociate the marriage and overule the permissible purpose granted by being in a community property state?
Will the new open-end reporting threshold of 200 originated lines in each of the two prior calendar years also go into effect as of July 1, 2020?