Our consumer loans are completed electronically and therefore we no longer print a loan application. Are there any compliance implications if it's not evident by viewing the on-line application, that the financial questions were asked of the borrower(s)?
I have a few questions. We have an on-line web application with our company and the question has come up as it refers to compliance. We are looking for confirmation as to when an application from a web application is considered an actual application: <ul><li>Is it when the borrower submits the minimum amount of information or a low loan amount (our site refers loans to our officer when the amount is below $50,000) and no credit is pulled, but we have the saved information in the site that can be pulled and given to loan officers to call the borrower?<li>Is it when the borrower submits for credit and underwriting and they receive an approval or denial from the web site?<li>Is it when the loan officer contacts the borrower after either of the above and the loan officer and borrower determine this to be an actual loan application?</li></ul>
Is there software available to help me calculate the APR, ROR accuracy, high cost loans, and individual state compliance, i.e. Texas and compliance issues in general.
We have a POS and LOS system for our mortgage applications. My question is, if a Member starts an application on the website, runs a credit report but closes out of the system before they have finished the input and the Desktop Underwriter doesn't make a credit decision, does this loan have to be submitted to HMDA? It can't be pushed to our LOS system without the DU response and is considered an "unsubmitted" by our company. Please advise.
With the help of technology and consolidation of processes, several lenders are concentrating efforts on lending to home buyers who are building their homes.
Does a subsidiary of a bank holding company, which is not a bank, have to display the Equal Housing Lender Logo on its website?
Electronic document companies are working with mortgage technology companies to create a way to complete the entire loan process using an electronic file. Advectis, Inc. and Dexma, Inc.
Does the "Equal Housing Lender" logo have to be in a particular location or a particular size on a handout? What about a poster?
Several bank regulations (Reg Z, B, M, etc.) have been amended to allow for and provide guidance for providing disclosures electronically. What about RESPA disclosures? Can we provide them electronically and if so, under what conditions?
When advertising student loans on a Web site, does it matter if the bank includes the Equal Housing Lender legend and logo. It is much simpler for the bank to include the legend/logo in the frames that appear on every page rather than miss including it on required pages.