Most Popular Lending Content
Data in a loan officer exception report
08/04/2024
What data fields should be included in a loan officer exception report?
Change in terms on an ARM loan – to the customer’s benefit – so are new disclosures needed?
08/04/2024
We are doing a change in terms to modify a consumer’s ARM loan. We are reducing the margin to make up for a higher index rate when the rate adjustment hits, and are resetting the adjustment period from 5 years to 3 years. The customer is benefiting from this change (the rate will actually go down just a touch), and they are signing a CIT agreement. Is this OK to do with just a CIT agreement?
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.
Commercial Revolving Line of Credit
07/28/2024
This concerns a commercial revolving line of credit that is secured by the borrowers' home. This loan is done in the individuals' names and the purpose of the loan is to purchase, renovate and sell investment houses. The thing that is confusing me is that they aren't making purchases or renovating with the line right now. Would this loan still be HMDAreportable since it is secured by the borrowers' primary residence?
Reducing paper, keeping auditors happy
07/28/2024
Why might auditors prefer accessing digital loan files instead of paper?