Reasons for Denial and Joint Applicants
12/24/2023
When sending an adverse action letter for joint applicants with different reasons for denial, can I use two letters (one for each applicant) for all denial reasons combined?
You can reach Randy via email at: careyrandy@comcast.net
12/24/2023
When sending an adverse action letter for joint applicants with different reasons for denial, can I use two letters (one for each applicant) for all denial reasons combined?
12/24/2023
When securing a loan with an assignment of leases and rents, how much could be advanced compared to value of the lease assignment? Is there any "standard" which is acceptable?
12/17/2023
Are short term loans (loans that will not be satisfied and replaced with permanent financing; paid out in full instead) subject to HOEPA and HPML? I see that temporary loans and bridge loans -12 months or less (loans that will be satisfied and replaced with permanent financing) are not subject to HPML. I believe temporary and short term loans are subject to HOEPA though.
12/17/2023
Are there alternatives to extensions are others using when dealing with construction-to-perm loans that are not finished my maturity? We are considering the possibility of advancing any remaining proceeds available on the loan to a checking account, which would have a hold to prevent use outside of the original agreement, and starting P&I repayment rather than extending the loan. We would continue to draw those funds to complete construction, just from the checking account rather than the loan itself. Curious if there are any drawbacks or compliance issues with this method.
11/19/2023
Our borrower inherited half of her father's farm. We made a loan for her to buy her sister's half. The loan is secured by the farm. Our customer is going to rent out the land and the home. She won't be farming it herself but will be receiving rental income from it. Does this qualify for the agricultural exemption for HMDA?
11/19/2023
Is the Home Loan Toolkit required to be given when no address is listed (such as a pre-approval) for a home purchase loan?
11/12/2023
We have a customer that is a US citizen and resides in the US. He is employed by a company in Australia and the company is doing business in Arkansas, It is a lithium battery business. The people associated with it are Australian citizens, with no U.S. tax IDs. What do we need to be in compliance with BSA if we do open accounts for them?
11/12/2023
Would a CTR be required if several individual employees endorsed their respective payroll checks (all individual payroll checks are under $10,000 but combined they aggregate to an amount that exceeds $10,000), and the owner of the business (which is exempt phase 2) cashed them for the purpose of distributing the proceeds back to the individual employees? Is this allowed under an exemption? PS - Our Compliance BSA Officer abruptly left the bank with no guidance, and we are trying to make sure we do things correctly.
11/12/2023
May we run an ad offering a $3.00 gift to people who open a new account and current account holders, without offering the gift to the general public?
11/12/2023
I have a UTMA account where the custodian (mom) has lost contact with both the bank and the child. What can we do as the bank to pass the funds to the child who is currently only 13?