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?
05/05/2024
Could you benefit from an update of all the lending regulations facing your FI in 2024?
04/28/2024
Is your FI ready for all the regulatory changes and updates facing you institution in 2024.
04/21/2024
What lending updates do we need to be ready for in 2024?
03/17/2024
Our residential mortgage lending team is very thorough to ensure that the Lending Committee signs-off on adverse action/denial documentation. We are newer to commercial lending. Thus, the Board approves all commercial loans.
The commercial lending officer has been given the discretion to decline certain requests before they even get to the Board. The question is more of a compliance/procedural one. Is it sufficient for only the commercial loan officer to sign-off on adverse actions, or should we be obtaining Board sign-off on these as well....under our current approval structure?
10/02/2022
If we accidentally deny a loan that has already been withdrawn by the borrower, prior to our credit decision, how should we handle the reporting of the HMDA data on the LAR? Should we report it as withdrawn per Reg C regardless of the existance of the denial letter, or should we report it as denied because there was a credit decision and letter issued and that's the action taken by the bank?
07/10/2022
I'm looking for some clarification on the Notice of Action Taken provided to businesses with revenues in excess of $1MM.
Can a Bank choose to provide these businesses with an Adverse Action Notice which lists the reasons for denial, or is the Bank required to provide the Notice of Action Taken which does not list the reasons for denial? I wasn't sure if there were any reasons that would prevent us from providing an Adverse Action Notice as opposed to a Notice of Action Taken.
Also, the provision does give the Bank the flexibility to notify the applicant, orally or in writing. If the applicant is notified orally, what would be the best course of action that the Bank or Loan Officer would need to take for compliance monitoring purposes?
"(ii) With regard to a business that had gross revenues in excess of $1 million in its preceding fiscal year or an extension of trade credit, credit incident to a factoring agreement, or other similar types of business credit, a creditor shall:
(A) Notify the applicant, within a reasonable time, orally or in writing, of the action taken; an
(B) Provide a written statement of the reasons for adverse action and theECOA notice specified in paragraph (b)(1) of this section if the applicant makes a written request for the reasons within 60 days of the creditor's notification."
05/01/2022
We have a business entity request for commercial credit and a credit report was pulled on the two owners, with the credit request denied based on one owner's credit score.
If the FCRA portion of the Adverse Action Notice is completed is that wrong?
If this is included and the score, key factors etc. are for the credit score used in making the credit decision is sent to both owners, in the name of the business entity, is that wrong?
04/24/2022
If I am doing a loan for an LLC where two partners own 40% each and the third owns 20%, do I need any information/documentation on the third owner if he is not going to be a borrower on this loan? Would meeting minutes be required where it is decided the third owner will not be signing the loan?
09/06/2020
We don't make owner occupied mortgages, but do make business purpose loans for rental properties. Do we need to continue using the Equal Housing Lender logo in advertising?