Most Popular Lending Content
FCRA Signature Required?
10/27/2024
We are transitioning to a new loan software program and have noticed the Negative Information Disclosure document provided at closing is not providing a signature line for the borrower to sign. Our current loan software has the signature line that isn't removable so we have always assumed it was required. I cannot find any information in the regulation that a signature is required. 1) Is a signature required and 2) If it is not required to obtain signature, is it required that we retain a copy of it with the closing package to show examiners it was provided at closing? It just seems odd from what we have always seen and would like to know if we should request a signature line be added.
Appraisal timing and fair lending
10/20/2024
If a financial institutions normal process for commercial property loans is to start appraisal bids/engagements post-decision, can there be fair lending violations for starting appraisal bids/engagements pre-decision for customers based on length of relationship with the financial institution, credit exposure with the financial institution, etc?
Selective reporting to credit bureaus
10/20/2024
As part of an initiative to be able to sell to secondary market we need to set up reporting to all credit bureaus. Currently we only report to Equifax. I am wondering if there are any compliance concerns if we only report to all bureaus for some loans (mortgage loans) and not others (in house branch originated) or mortgages vs. other loan types, commercial vs consumer, etc?
Call report codes and agricultural use land
10/20/2024
We have a number of residential loans that sit on several acres of property that i would consider 1B if it were vacant, i.e., "usable for agricultural purposes." Should these be classified as 1C2A or 1B on the Call Report? The definitions leave room for interpretation. For example, a loan for a single family residence that sits on 100 acres.
Expiring documents at financial institutions
10/20/2024
Why do some banking documents expire?