08/16/2004
As we put together our 2005 budget, how can we increase our revenue forecasts for mortgages and consumer lending in an environment with rising rates?
08/16/2004
For HMDA, what is the delineation between a modified loan and a refinanced loan? Say a loan's terms are changed (went from interest only to an amortizing basis) but the loan number remains the same. Is this dependent on the same test for Reg. Z, a replacement of the loan document?
08/16/2004
Is it a requirement that the customer date the Flood Notice when they sign it?
08/16/2004
If a lender takes only basic inquiry information so it can review a credit bureau report, and later takes an application for a mortgage loan, is the date of application the date we pulled the credit report, or the date we got the complete application?
08/16/2004
The Finance Charge rule is that if it is understated by $100 or less or if it is overstated it is deemed accurate. I have recently ran into situations where some companies are using a $35 tolerance. Has the finance charge rule changed?
08/02/2004
How can residential lenders easily expand their lending footprint and borrower reach while maintaining cost control and efficiency?
08/02/2004
The filing period of a financing statement is 5 years and one of the exceptions is "Cooperative Filing - effective 50 years." For example, if we (the bank) had granted a 15-year co-op mortgage loan to the customer several years ago and filed a UCC-1 on the unit at that time, would this UCC filing be effective for 50 years and would we not have to file a continuation every five years?
08/02/2004
It is clear under the new rules that both the race and ethnicity sections must be completed when required. However, in my part of the country (Texas), the vast majority of Hispanics are of Mexican descent. Based upon the OMB racial definitions, there does not appear to be a single race category that applies to most Hispanics. And, most of the time, from what I am seeing, Hispanics will not check the race category, leaving loan officers with the responsibility of using the OMB definitions (per the FFIEC's instructions), which provide no help. What do you suggest a bank should do in selecting the race for Hispanic applicants?
08/02/2004
What term should we use on an ARM loan in the Rate Spread Calculator? For example, does a 5/1 ARM with a 30-year amortization use the 5-year Treasury?
08/02/2004
I believe that the practice of providing the "Right to receive a copy of Appraisal" at closing is acceptable and represents the "notice of action" in an approved loan. Others feel that we should provide a separate mailing sometime between the application date and closing date when the decision to approve the loan is made. I think this is more cumbersome than it needs to be. What do you think?