03/23/2025
I am working on a process to comply with 1071 small business data collection. We have an automated system that will collect and keep the demographic information behind the fire wall. My question is what about the customers who don't use email or technology? Any ideas on how we
can collect and keep this information secure? Have you heard what other FIs are doing in this situation?
01/12/2025
Currently our Cascade Alerts only provide that a customer did an application for a Mortgage or Home Equity at another bank, but does not provide any details as to what they applied for. If we were to utilize an option with Cascade Alerts on our Mortgage and Home Equity customers where we would be able to know what type of loan the customer applied for at another bank (Mortgage or Home Equity), what would we then be required to provide disclosure wise to the customer?
11/24/2024
Can you remove the primary borrower off a pending loan? I was under the impression that as long as both borrowers were married, and they both completed the application and received the initial disclosures that the primary borrower could be removed and the co-borrower moved over to the primary borrower position. This was the only way, and any other attempt would result in a denial, or withdrawn application.
We have done this with a couple of our loans, but upper management wanted documentation stating that this can be done.
10/13/2024
Is there an ECOA/Regulation B delivery requirement for an appraisal final inspection to the borrowers prior to closing if the initial appraisal has already been delivered?
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?
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?
12/24/2023
When sending an adverse action letter for joint applicants with different reasons for denial, can I use two letters (one for each applicant) for all denial reasons combined?
11/05/2023
There is confusion over the disclosure for the Reg B, Right to Receive Copy of Appraisal.
I read that David Dickinson (Aug 9, 2010) said there is no date requirement for this disclosure, whereas Dan Pesfull advised it is given at or within 3 days of application but can be given at closing. Per the CFPB website it must be given within 3 business day of receipt of application. (12 CFR § 1002.14(a)(2). Can some one clarify.
07/02/2023
When an applicant emails a mortgage loan application, when it is considered received by the bank? When does the disclosure clock start to run?
06/04/2023
Regarding the new small business data reporting requirement expected to come out soon. Will this "1071" requirement be similar to HMDA and CRA whereby if it’s HMDA it cannot be reported as CRA? So if it’s a HMDA reportable loan, then we won't report it for the small business data?