10/01/2012
Regarding SAFE Act compliance - the "Relation to Other Laws" section on page 9 of the March 2012 CFPB Safe Act guide - seems clear the MLO's NMLS number must be included on the loan application. BUT - if the loan is going to be kept in-house and not sold to the secondary market - is it still necessary to include the MLO's NMLS number on the loan application?
09/24/2012
When a Commercial Department is presented with an opportunity to provide a term sheet for a commercial loan - prior to receiving a loan application - is this request to be considered a loan application? Does HMDA reportable issue apply if the bank never received a loan application and there is no loan decision?
09/17/2012
When a commercial department is presented with an opportunity to provide a term sheet for a commercial loan - prior to receiving a loan application - is this request to be considered a loan application? Does a HMDA-reportable issue apply if the bank never received a loan application and there is no loan decision?
08/20/2012
A consumer loan application was taken by phone. The next day the customer withdrew the application because she had decided to finance through the furniture company which offered 12 months same as cash. At the time of application, the lender pulled credit and printed the Insurance Disclosure for Credit Application. Does the Consumer Credit Score Disclosure and Insurance Disclosure need to be mailed to the applicant even though the application was withdrawn and never signed?
08/13/2012
Once we take a residential mortgage loan application over the phone, we send the 1003 and initial disclosures to the applicant. Would we be prohibited from providing a written notification with the loan package that instructs the applicant to return the documents to us within 14 days or the bank will consider the application to be withdrawn by applicant?
07/09/2012
Assumption: A credit report was pulled on our customer on January 25, 2012 and a loan was funded at that time. The customer comes back on April 14, 2012 to get another loan. Question: If we used the same credit report originally pulled on January 25, 2012 to base our approval on the second loan, should the loan Officer send the customer a second Credit Score Exception Notice using the same information that was given to the customer on January 25, 2012. Should each new loan have a "new" Credit Score Exception Notice as part of the loan package? Our officers are just copying the "old" notice and inserting it the new loan package? Our LaserPro documentation allows us to put the date of the new loan application (04-14-2012) but the officer is just copying the old notice with the application date of the original note?
06/18/2012
Assume that a credit report was pulled on our customer on January 25, 2012, and a loan was funded at that time. The customer comes back on April 14, 2012, to get another loan. If we used the same credit report originally pulled on January 25, 2012, to base our approval on the second loan, should the loan Officer send the customer a second Credit Score Exception Notice using the same information that was given to the customer on January 25, 2012? Should each new loan have a "new" Credit Score Exception Notice as part of the loan package? Our officers are just copying the "old" notice and inserting it in the new loan package. Our LaserPro documentation allows us to put the date of the new loan application (04-14-2012) but the officer is just copying the old notice with the application date of the original note.
01/02/2012
For a HMDA-reportable loan application that was approved, accepted but failed to be closed before the deadline stated in the commitment (due to inaction by the applicant). Should it be reported as a denial or application approved but not accepted?
10/17/2011
When doing construction perm loans, is it necessary to get a new loan application on the loan if you initially did the interim-construction loan? If not, how do you document the application date for disclosures on the permanent loan and HMDA?
09/05/2011
Can you deny a loan before having the customer fill out a loan application and pulling a credit report?