Most Popular Lending Content
Interpreting HMDA definitions
02/23/2025
We are in the middle of HMDA verification for filing and have had some questions arise we cannot seem to find a clear answer to: 1. We have a loan that was made to pay down the primary residence portion of another existing loan with our institution and the collateral was released, but the existing loan remains open with security now of cattle, a cattle trailer, and vacant land. Under HMDA, a refinance is defined as the satisfaction of an existing loan, but is there guidance for whether "satisfaction" is only full payoff of the existing loan or can this be interpreted to also include satisfying the portion of the loan that was dwelling secured? 2. We have a loan that is secured by a dwelling. Currently we are reporting as one unit but looking at the appraisal, the property also has a living space over the garage that includes a living room, bedroom, and bathroom. Our HMDA team is of the opinion that because there is not a kitchen it is not considered a dwelling but we cannot seem to find guidance that would specify what components would constitute a "dwelling" under Regulation C other than a "residential structure". Is this interpretation correct?
Policy exception tracking systems
02/23/2025
How do financial institutions track policy exceptions?
Commercial credit analysis teams
02/16/2025
What is a commercial credit team?
Exception challenges and commercial credit analysis
02/16/2025
How can missing documents create issues for commercial credit analysis?
CRA Credit and Income Verification
02/16/2025
When reviewing a loan for CRA credit, should we use income from form 4835 (Farm Rental Income and Expenses) as part of the gross annual revenue? Per the customer, rents in FYE 2022 are from leasing out the rice ground as they did not farm it themselves in 2022 due to water shortage.