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RESPA Coverage

06/14/2010

Do all one to four family homes, rental properties etc., require RESPA? Does twenty-five acres with a home on the twenty-five acres require RESPA?

Original Application was Withdrawn

04/05/2010

During a recent audit, I came across a consumer loan file where the application date and disclosures were not matching up. After questioning the lender, it turns out thethat customer initially applied for a HELOC, but then about a week later changed his mind about the product type, and went with a HE closed loan. I told the lender we should have kept the initial documentation for the HELOC in the file and noted that there was a product change on xx/xx/10, so that there would not be any questions on if the appropriate disclosures were provided to the customer. The lender stated that the application for the HELOC was withdrawn, so that documentation was not necessary to keep in the file. I didn't feel this was indeed a true withdrawn application on the initial product request. What do you think?

Fair Lending - Incomplete Application

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due to incompleteness is incomplete (5) and coded as such, but for Fair Lending purposes, is the file considered withdrawn or denied?

HMDA - Loan Prequalification

02/15/2010

This question is regarding Section 203.1-1(c)Scope2. If a broker has a loan officer that prequalifies applications based solely on the data on the application, is that making a credit decision for HMDA reporting purposes? Once the loan officer sends the prequal approval, disclosures are sent out and the borrower signs the disclosures and returns them with income/asset/property documentation to process the loan. Once processed, the loan file is submitted to the investor's underwriter for approval. Is the investor making the credit decision? Once investor underwriter approves and clears the file to close, we close in our name, manage the construction loan and when construction is complete, we sell the loan to the investor.

Withdrawn/Denied Commercial Loan Applications

02/01/2010

What are the regulations on withdrawn loan applications for commercial loans? What is the threshold on commercial loans that are denied as to when to send out an adverse action form?

Refinance/Additional Money - New App Required?

01/25/2010

Does a bank have to get a new completed application for a refinance of a home loan with no new money? If they also get additional money to do something, such as home improvement, do they have to get a new application?

Second Review for Denied Applications

06/15/2009

Is a second review required for denied applications for real estate secured loans (first mortgage and/or home equity), and if so, which regulatory guideline or law mandates the review?

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Change in terms on an ARM loan – to the customer’s benefit – so are new disclosures needed?

08/04/2024

We are doing a change in terms to modify a consumer’s ARM loan. We are reducing the margin to make up for a higher index rate when the rate adjustment hits, and are resetting the adjustment period from 5 years to 3 years. The customer is benefiting from this change (the rate will actually go down just a touch), and they are signing a CIT agreement. Is this OK to do with just a CIT agreement?

Commercial Revolving Line of Credit

07/28/2024

This concerns a commercial revolving line of credit that is secured by the borrowers' home. This loan is done in the individuals' names and the purpose of the loan is to purchase, renovate and sell investment houses. The thing that is confusing me is that they aren't making purchases or renovating with the line right now. Would this loan still be HMDAreportable since it is secured by the borrowers' primary residence?

Intent to apply for joint credit

07/21/2024

In reviewing our Consumer Loan Application, I noticed there is no formal Reg B section in which the Borrower(s) indicate whether they are applying for individual credit or joint credit. In my prior employment, the applications always included a formal Reg B section. Is this formal section required?

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