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Latest Lending - Mergers/Acquisitions Topics

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.

Disclosures on Mortgage Loans after Acquisition

08/04/2019

We went through a merger and acquired another bank's assets. With the bank's name changed, what disclosures do we need to give on mortgage loans we are servicing as a result of the acquisition and what information needs to be on there?

Networking

11/26/2017

How do I build my professional network?

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45 day letter/forceplacement time frames

12/15/2024

We have a question on the 45 day letter/forceplacement time frames. Can you give an example of the timing when a policy expires on 12:01 am on April 1st. The 45 day letter would go out on the 1st, when would you actually forceplace; the 46th day after the date of your letter? Please also clarify the FEMA lapses due to funding. Were you saying that if we have a FEMA policy in place and the government lapses the program, we are required to have them obtain a private policy or we need to start our 45 day forceplace process until the government reinstates the program?

Life of the loan

12/15/2024

What does the phrase “life of the loan” refer to?

Force Placed Insurance Question

12/08/2024

We are looking into changing our procedures regarding force placed insurance, on both hazard and flood. Currently, we have been increasing the principal balance of the loan and including the premium in our coverage amount. We have not however; on flood, been pulling another flood determination or providing a new flood notice. We thought since they were “life of loan”, we were ok. We are wanting to change the procedure, to adding the force placed insurance as a fee and renewing/charging at time of balloon. My question is…are we in compliance if we only cover the principal balance and not include the payoff (which will contain our premium)?

TRID Question

12/08/2024

We closed a refinance transaction on Monday and gave the 3 day right of rescission. The loan was for $250,000 and is a 15 year. This morning he contact us and they are starting to worry about the payment amount on the 15 year. They are asking if they can pay down $50,000 and change the term to a 30 year. We have not ever had this happen. Our question is does this trigger then to use the 3 day and cancel the transaction and start over or do we fund the loan into our MPF program, wait the 60 days and then do a modification?

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