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Census Tract # for Small Farm Loans
03/04/2013
It is my understanding that with small farm loans, the shop headquarters is to be use for the census tract number. If a loan is for farm equipment or something that will be used on the farm, is the headquarters census tract used for that too or can the farmer's residential address be used for the census tract number?
FCRA Requirements-Adverse Action for Joint App
03/04/2013
The Fair Credit Reporting Act requires that each applicant (assuming there is a co-applicant) receive an FCRA adverse action notice in the event of an adverse action. Assume that there is a joint application for an installment loan, not secured by real estate (auto loan for example). The loan is denied because after a review of the credit reports of both applicants, the primary applicant previously filed for bankruptcy and the co-applicant has delinquent obligations with creditors. Should each separate notice provided to the applicant and co-applicant only list the reasons specific to their own credit history? In other words, should the applicant's notice only reference the bankruptcy and the co-applicant's notice only reference the delinquent credit obligations? My reasoning for feeling this way is that 1. it protects the privacy of the applicant and co-applicant and 2. it will better inform the applicant and co-applicant of what specific reasons were used in their denial so that each individual may correct them in order to secure the credit in the future. I understand only one would need an ECOA notice but my concern comes specifically from FCRA notice requirements.
Certificate of Deposit for Collateral-Wrong #
03/04/2013
We have taken a certificate of deposit for collateral on a loan. The officer printed the assignment of deposit with the collateral description reading all existing and future accounts instead of the CD and number we actually took. Are we covered if the loan defaults?
When Should A Rate Be Locked In
03/04/2013
I have researched when a rate should be locked in. I say it is before loan closing but I am being told it can be after closing.
Reg B Spousal Consent to Pledge Community Assets
03/04/2013
Is it legal to ask a non - owning spouse to sign a Spousal Consent to pledge community assets on a commercial loan where the Reg B questionnaire is clearly marked not applying jointly?