03/17/2024
Who should manage the NMLS registration for our Mortgage Loan Originators (MLOs)? Is that an HR function, or should compliance do it?
03/17/2024
Our residential mortgage lending team is very thorough to ensure that the Lending Committee signs-off on adverse action/denial documentation. We are newer to commercial lending. Thus, the Board approves all commercial loans.
The commercial lending officer has been given the discretion to decline certain requests before they even get to the Board. The question is more of a compliance/procedural one. Is it sufficient for only the commercial loan officer to sign-off on adverse actions, or should we be obtaining Board sign-off on these as well....under our current approval structure?
03/10/2024
Must our Loan Originators (LO) be registered on the NMLS Registry?
03/10/2024
I work in operations, and our Executive Vice President just showed up on the daily NSF report! He has overdrawn his personal checking account by $1,200. What do we do?! Can we pay it or must we return it, and must we charge him our normal fee?
03/10/2024
Is flood insurance on the contents of a property required if the property is located in a SFHA?
03/10/2024
If our bank does not offer a rate lock program and all of our loans are fixed rate loans, can a buyer purchase discount points to lower the interest rate? If they can, do they have to sign a form reflecting the discount rate or can we just disclose the discount and fee on the loan estimate?
03/10/2024
We are transitioning to a new loan software program and have noticed the Negative Information Disclosure document provided at closing is not providing a signature line for the borrower to sign. Our current loan software has the signature line that isn't removable so we have always assumed it was required. I cannot find any information in the regulation that a signature is required. 1) Is a signature required and 2) If it is not required to obtain signature, is it required that we retain a copy of it with the closing package to show examiners it was provided at closing? It just seems odd from what we have always seen and would like to know if we should request a signature line be added.
03/03/2024
We made a loan to a borrower for the purchase of 2 mobile homes located in a mobile home park in Florida. The homes are “strapped down” to meet state/local requirements and have electricity and plumbing. However, we feel the home can be disconnected and moved and would not require us to perform a flood determination. Are we correct?
03/03/2024
I thought that the CFPB came out and said that banks could no longer engage in MSAs because of a large enforcement action?
03/03/2024
To avoid Reg O conflicts, we are thinking of granting a loan to an executive officer that is secured by a CD at our bank. Does this type of collateral eliminate any Reg O concerns?