03/22/2010
Our bank will be reporting Home Equity Lines of Credits for HMDA. Although we are not certain what the guidelines are for the loan amount, we understand we have to report only the amount intended for home improvements. For example, do we use the amount they draw at closing? Please clarify how to determine what amount to use.
03/22/2010
Are there any changes being made to the application associated with the new RESPA changes?
03/22/2010
I understand that as far as HMDA is concerned, an application that cannot be considered due to incompleteness is incomplete (5) and coded as such, but for Fair Lending purposes, is the file considered withdrawn or denied?
03/08/2010
When does the new good faith estimate form go into effect?
02/08/2010
In business credit, Regulation B states oral notification needs to be documented; what does this mean and entail?
02/01/2010
Do we need to provide a TIL disclosure within three business days of receiving an application for a construction loan on applications received after July 30, 2009? Our construction loan term is twelve months or eighteen months. Are we allowed the temporary financing Reg Z exemption under the new MDIA ruling?
01/18/2010
Are Higher Priced Mortgage Loans for loan applications dated on or after Oct 1, 2009? How would you suggest banks handle ARMs that have been on the books prior to 10/01/09? Would these fall into the HPML when these get re-priced?
01/18/2010
We have some customers that present us what is called the United Nations passport as form of identification. On their applications they state their nationality. For a while, we have considered that ID as valid, but now we are having second thoughts. Would you accept that form of ID? I understand it is not issued by the government, but it has a picture, signature and expiration date and is accepted for crossing borders.
01/11/2010
The changes to RESPA by HUD includes a revised definition of application. One of the elements which make up an application is described as "an estimate of the value of the property". How should this be documented on the application form to ensure compliance? The residential loan applications which are provided in our loan processing system (ARTA) do not have this item included on the form.
10/12/2009
Am I correct in stating that the TIL must now be given early and there is not an additional one required unless APR becomes inaccurate?