02/16/2020
How can we improve our portfolio concentration analysis?
06/02/2014
Our appraisal operations team uses a software platform and appraisal management companies to handle our appraisal pipeline. How do the CFPB and OCC view third-party service providers like this? What's our liability?
06/02/2014
Our appraisal operations team uses a software platform and appraisal management companies to handle our appraisal pipeline. How do the CFPB and OCC view third-party service providers like this? What's our liability?
05/19/2014
How do the new Third-Party Oversight requirements affect appraisal operations?
02/25/2013
HMDA Refinance - We had a HMDA data integrity review recently and the examiner stated that a loan cannot be recorded as a refinance unless the funds originally went to purchase the home. She referred us to the OCC HMDA handbook for guidance regarding refinancing. I question if the interpretation is being confused by the definition of coverage vs. reporting. In looking at the FFIEC/HMDA FAQs one example is where a home equity line of credit with a junior lien is converted to a term home equity loan. Would this not be reportable for HMDA as a refinance?
09/24/2012
If a person borrows money to do home improvements to a home they do not own but will be renting; is that reportable as home improvement - not owner occupied? We classify and report all of our unsecured home improvement loans.
11/21/2011
A National Bank customer defaults on an installment loan due to delinquency and the loan is charged off on December 31, 2002. The customer continues to make payments and brings the loan current in 2005. The customer asks the bank to rebook the charged off loan, the bank agrees and a new loan agreement is signed in March 2006. In December 2006, the OCC regulators tell the bank to charge off the new loan (their reason: a bank can not rebook a charged off loan) even though the loan was current and paid as agreed. Since the customer was not at fault and the bank was in error to rebook the loan, how does the bank report the loan to the credit bureau? Do they use the original date of December 2002 or December 2006?
08/15/2011
I have tried to use the APRWIN Calculator on the OCC website. It is showing a particular type of loans as violations. Our Chairman of the Board wants me to manually check these. Is there a formula I can use to manually check these APR's?
08/08/2011
I have tried to use the APRWIN Calculator on the OCC website. It is showing a particular type of loans as violations. Our Chairman of the Board wants me to manually check these. Is there a formula I can use to manually check these APR's?
11/29/2010
How can I figure TIL reimbusement on an OCC APR WIN calculator for loans with interest only payments and all principal due at maturity with fixed rate? I am not sure what to list on my payment stream when each interest payment can be different each month.