03/03/2024
When a renew a loan with collateral should a new Security Agreement be completed as well?
02/25/2024
We are making a loan to a business customer to purchase a new apartment building. The apartment building is not located in a flood zone. The loan approval requires the cross collateralization of two additional properties owned by the borrower. Do I need to obtain flood determination on these properties?
02/25/2024
Is it a problem if the mortgage brokers that we use invite some of our lenders to parties to celebrate milestones like year-end celebrations where loan closing goals were met?
02/25/2024
Who is an “Executive Officer” under Reg O?
02/25/2024
Can you remove the primary borrower off a pending loan? I was under the impression that as long as both borrowers were married, and they both completed the application and received the initial disclosures that the primary borrower could be removed and the co-borrower moved over to the primary borrower position. This was the only way, and any other attempt would result in a denial, or withdrawn application.
We have done this with a couple of our loans, but upper management wanted documentation stating that this can be done.
02/25/2024
Our marketing department brought up the idea of handing out $50 coupons to our customers to entice them to refer folks to get a mortgage loan with the bank. The idea is that if a customer refers someone for a mortgage loan and it closes, the customer can redeem the $50 coupon for cash. I reviewed 1026.36 but it only seems to cover MLO compensation. RESPA's 1024.14(b) seems most applicable but i'm not sure if that just pertains to the parties involved in the transaction. This would be a referral for our customer who told someone to get a mortgage with us.
Are there any regulations on a $50 referral ‘bonus/compensation’ to our customer for referring someone to one of our MLO’s to close a mortgage? It seems similar to what the big banks do with something like a $200 bonus to open an account with them.
02/18/2024
Our bank president is a signer on a local non-profit’s checking account. That non-profit just bounced a check – does Reg O come into play here? Can we pay the OD and waive the fee?
02/18/2024
We have a commercial loan on farmland with 12 outbuildings and a dwelling. Only one of the buildings (a small barn) is located in a flood zone that requires insurance. The loan amount is $500,000 and the appraiser valued this building at $70,000. Because only a small percentage of the secured collateral is in a flood zone, is flood insurance still required?
02/18/2024
Would it be considered an issue if we “favor” the loan applications that are sent to us from one real estate agency over another if they just send us more of them?
02/18/2024
I'm new to the compliance world and brand new to this institution. I just received an external audit from a consulting firm that cited multiple MLA findings for obtaining applicant's MLA status for an exempt transaction (vehicle purchases). Our credit reports include the MLA check automatically. Are those legitimate findings? Do we need to turn off the MLA check that's part of the credit report?