Non-real estate loan applicants can use our online form to request a loan. Based on their address we will know if they are in or out of our market area. In some cases an online request is stopped before a credit report is pulled and the person is not allowed to complete the application because they receive a message saying they are outside our market area. The bank does not send any other other notification. Are we required to send an adverse action notice if the bank's practice is to not make these type loans outside of our service area?
This question is regarding incomplete mortgage applications with an address. (ie: Refi's) Here is the scenerio: Bank approves an application based on the information provided by the consumer, mails the approval letter out which states that based on the application and credit report their loan has been approved subject to the verification of income, assets, and any additional documents deemed necessary from underwriting.
The lender then sits on the file for several months without contacting the customer and then withdraws it stating it is being withdrawn due to no contact.
Should this considered an incomplete application based on the consumer not getting the required documentation to the lender or can it be considered withdrawn since there was no contact with lender since the approval letter?
We use combined DTI for underwriting purposes. Regardless of whether joint applicants are married, unmarried, living in the same household, etc. we would need to be consistent with this underwriting practice and consider combined DTI? We shouldn’t look at individual DTI on unmarried joint applicants who for example don’t live at the same household?
Joint application is received by the bank with one applicant having excellent credit and the other having terrible credit. For AAN purposes, if we provide the specific reasons for turndown to the terrible applicant such as repossession, delinquent past/present credit obligations with others, etc. and then provide an AAN to the excellent applicant, we should re-state repossession, delinquent credit obligations, etc. on the excellent applicant’s AAN as well - even though these reasons don't specifically apply to the excellent applicant himself, but are the primary reasons for the turndown. Correct?
We have a procedure built into our loan program, in which loans with a co-signer are assessed an additional .50% rate increase. Co-signed loans are set up for individuals with limited or no credit file, not for individuals with derogatory credit. The individual co-signing on the loan must have excellent credit. Recently we found a situation where the application was submitted as joint applicants (with joint intent completed), but we structured as a co-sign loan, rather than just looking at the loan as a joint loan, and so we assessed the additional .50% rate increase. Could this practice be considered discriminatory?
Do you recommend including a complaint entry item to identify servicemembers?
The loan estimate must be delivered or placed in the mail not later than the third business day (general rule) after receipt of the consumer's application. As long as you can document that the email was sent not later than the third business day you will be fine.
How is the "In 5 years" disclosure completed for short-term construction loans?
For a home improvement loan, is the Purpose = Home Equity?
How is interest estimated for a multiple advance construction loan?