06/18/2007
Even though Part 365 of the Real Estate Lending Standards states that a 1-4 family owner occupied LTV percentage is 85%, is it acceptable to go to 90% if our loan policy discloses such?
06/11/2007
I have two questions in regards to Reg O Insider Loans. Are executive officers required to report extensions of credit from Credit Unions to their member bank? Second, are extensions of credit for mortgage loans and loans to finance education subject to the condition in writing that the extension of credit may become payable at any time the executive officer is indebted to all other banks greater than the member banks aggregated lending limit?
04/16/2007
On a commercial loan with guarantors, why is it best to process the loan using guaranty agreements instead of processing as co-signers or co-borrowers? We have loan officers that insist on processing the loan with the guarantor as a co-signer.
10/09/2006
What are the bank policies that need board approval and how frequently?
09/11/2006
We have recently hired some new loan officers and they have always been told that they cannot order their own appraisals. Is there anything in the regs that prohibits a loan officer from ordering appraisals?
08/14/2006
In reference to the question below, would you also be required to report a loan to a mortgage company that is not affiliated with any bank? Ex Officer Reporting Loans from other Banks by Randy Carey, BOL GuruQuestion: Regarding Regulation O Section 215.9, relating to Executive Officer reporting loans from other "banks." Does this definition of Banks mean only members of the Federal Reserve? We are regulated by OCC and I looked in their Insider Activities handbook, but it only states "215.9 - Reports by Executive Officers "Executive officers" must provide a written report to the board of directors within 10 days of becoming indebted to any bank if the aggregate amount of the indebtedness exceeds $100,000 (or the greater of 2.5 percent of the bank's capital and surplus or $25,000). The report shall state the lender's name, the date and the amount, security, and purpose for each extension of credit."Answer: The term "bank" alone is not defined within the regulation. I would interpret it to be defined very broadly and would include any type of bank, whether a member bank or not. First published on BankersOnline.com 1/30/06
01/30/2006
Can you offer a special checking account to a select group of people, ie: they all work at the same place, without discriminating against other customers if they are not employed by the same company?
12/01/2005
Failures in lending compliance can cost as much as $14,000,000. That's the amount one lender will have to pay for unfair lending practices and compliance failures.
09/19/2005
Are there any Reg O or State of Nebraska laws/requirements for executive officers to report to the Board of Directors commercial loans that they guaranty when the loan is not at the subject bank, or any of its correspondent banks?
05/23/2005
What specific lending information should be reported to the board on a periodic basis?