03/24/2024
A broker sends a potential borrower to the bank. He wants to pre-qualify for a loan that will be a finished house in a builder's subdivision which is represented by the broker. The dwelling will not be finished for 6 - 12 months. The bank received the application from the broker and pre-qualifies (no pre-approval program) for a later date. There would not be any early disclosures at the type of the pre-qual, correct?
03/12/2023
For loans that take months from application to closing, at what point would you recommend collecting updated Customer Due Diligence? My initial thought is that as long as the loan had not closed, we can rely on the information from the previous 90 days, but would want to verify/update after that period, and I am having difficulty finding guidance on specific timing.
11/14/2021
What is the LAR Formatting Tool?
08/30/2020
What does an electronic pipeline management system do?
12/06/2015
What does BISG stand for, and what does BISG mean for Fair Lending Compliance?
09/07/2015
My bank offers consumer personal loans, and we recently hired a new underwriter for mortgage and consumer loans. Our new underwriter is saying that if the applicant shows no credit (no trade lines) from all 3 bureaus we must ask the applicant to supply us with four non-credit payment references. I know we have done this in the past for mortgages as we underwrite to Freddie Mac policies and this is one of their requirements to establish credit, but is this something that should be done for personal loans as well? We have never done this in the past.
12/24/2012
I am renewing a loan that was originally a HELOC. The loan matured and I collected an updated "consumer HELOC" application and obtained a new credit report. The loan was approved for renewal but for a lower amount and shorter term. I was told that I should not have collected a new loan application (purpose on application was stated a renewal of HELOC) because this is not a new loan request. No new disclosures were required and only a simple form modification agreement was needed to renew the loan. Can you please advise as to what documentation would be need for this type of transaction?
10/29/2012
If the original loan application package was issued for a husband and wife and signed by both but later changed the loan to husband's name only, can the original disclosures (not 1003) be used or would a new set be required in the husband's name with his signature only?
10/01/2012
Regarding SAFE Act compliance - the "Relation to Other Laws" section on page 9 of the March 2012 CFPB Safe Act guide - seems clear the MLO's NMLS number must be included on the loan application. BUT - if the loan is going to be kept in-house and not sold to the secondary market - is it still necessary to include the MLO's NMLS number on the loan application?
09/24/2012
When a Commercial Department is presented with an opportunity to provide a term sheet for a commercial loan - prior to receiving a loan application - is this request to be considered a loan application? Does HMDA reportable issue apply if the bank never received a loan application and there is no loan decision?