12/01/2002
Congress didn't carry out all of its responsibilities before adjourning in 2002.
11/18/2002
Will we need to obtain a copy of a driver license for a guarantor on a loan?
11/04/2002
Is a Right of Rescission required on a bridge loan for 12 months using their current primary residence as collateral. Purpose of the loan is to purchase a new primary residence.
09/16/2002
What is the first step a loan officer should take if a customer is taking advantage of the Soldiers' and Sailors' Civil Relief Act? Our customer has not paid in 7 months, has vacated the home, and has turned around and rented it to another family.
07/15/2002
Mandatory Flood insurance requirement on a loan with three properties as collateral. Only one is in a flood zone, however the value of the two that are not in the flood zone will more than cover the loan amount. What would be the amount of coverage to require the customer to purchase? The appraised value of the improvements, replacement cost seems to be only for residential property and this is a commercial building. The loan amount if $3,000,000.
07/15/2002
I noted on your Roadmap that you indicated a transaction subject to RA9, with security interested perfected under old A9, perfected by filing, in the correct state, with the correct filing, should be continued prior to the normal lapse date by an initial financing statement. I was under the impression that a correctly filed security interest subject to a UCC1 filing under old A9 that meets all the requirements of RA9 should be continued by virtue of a UCC-3 continuation within the window period prior to the normal lapse date, not by an initial filing statement. Please clarify the need for an initial filing statement. Up to this point, I had understood that the initial filing statement was the means to maintain your lien position at the same time you were "correcting" or bringing into compliance with RA9 a filing not meeting the requirements of RA9, but for which you had been perfected under prior A9.
07/01/2002
If we state an early withdrawal penalty in our disclosures for our Certificate of Deposits, but it is then used as collateral on a loan can we waive the fee if the customer chooses to pay the loan off early and cash the CD out?
06/17/2002
I have a question regarding the counteroffer/adverse action provisions of Reg. B. Does a change in the "terms" of credit only apply to rate, amount, loan term, or to other aspects of the transaction? For example, if we condition a mortgage loan approval on a new roof or other work requirements, does that constitute a counteroffer and would we have to provide an adverse action letter if the borrower doesn't want to perform the work and declines the loan offer?
06/03/2002
<a href="http://www.bankersonline.com/regs/202/202.html">Regulation B</a> Loan issued to an individual for the purpose of refinancing commercial property. Are we required to provide the "Right to Receive Copy Of Appraisal Notice"?
03/04/2002
Can a custodial account (certificate of deposit) be used as collateral on a loan for the Custodian, i.e., Jane Doe, custodian for Johnny Doe? It is not titled UTMA, but the minor's SSN is used on the CD.