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GFE Requirements

01/01/2005

Question: We originate investor mortgages on 1-4 unit owner occupied properties. One of our investors is asking for a Good Faith Estimate within 3 days of the Credit Report.

Discussing Credit Report Information

10/04/2004

How much information can a bank representative discuss with a loan applicant regarding their credit report without any lending regulations? I've heard everything from "nothing" to all but providing a copy to the applicant.

Credit Bureau Reports Without Written Permission

10/04/2004

Can you take applications for loans over the phone and pull credit? If the customer never comes in and the request is denied, what do you do with the application that has not been signed by the customer that gives you permission to pull credit?

Permissible Purpose to Access Credit Reports

09/06/2004

Under the "permissible purposes" rule in the FCRA, if a customer applies for joint credit but only one applicant is present to sign the application authorizing us to obtain a credit report, do we have a "permissible purpose" to obtain a credit report on the absent applicant? Do we need the absent applicant's signature before obtaining the credit report? Is the same thing true for deposit accounts when checking with ChexSystems? I have not been able to find anything indicating the customer is required to sign giving permission to obtain the credit report.

Permissible Purpose to Access Credit Reports

09/06/2004

Under the "permissible purposes" rule in the FCRA, if a customer applies for joint credit but only one applicant is present to sign the application authorizing us to obtain a credit report, do we have a "permissible purpose" to obtain a credit report on the absent applicant? Do we need the absent applicant's signature before obtaining the credit report? Is the same thing true for deposit accounts when checking with ChexSystems? I have not been able to find anything indicating the customer is required to sign giving permission to obtain the credit report.

When Is This An Application

08/16/2004

If a lender takes only basic inquiry information so it can review a credit bureau report, and later takes an application for a mortgage loan, is the date of application the date we pulled the credit report, or the date we got the complete application?

Notice for Withdrawn Applications

04/19/2004

If a loan application is withdrawn by the applicant, is it necessary that we send out an adverse action notice? Currently we have been sending out this notice stating "customer withdrew application" and marking the FCRA notice disclosure inapplicable.

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HMDA filing compliance involving an acquired branch

08/04/2024

We are currently in the process of acquiring a branch of another financial institution. I am by no means a guru in HMDA but certainly not in acquisitions and this is the first time we've done this in a long time (before my time). I am under the impression aftery some reading of the HMDA Getting It Right Guide, that we have to report the loans we obtain through the purchase. This is okay, but I have others saying that we only have to report the ones they originated in 2024, which I don't think is accurate, but I could be wrong. Additionally, the other institution's staff members aren't being very forth coming with information and have advised that we will get the information for the files we are getting, however, we will have to go through it to gather the HMDA required data, as they will not provide us with a LAR. I'm also trying to decipher the guide and if we qualify to not report certain fields, like Loan Costs, Origination Fees and Discount Points.

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?

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