03/22/2020
As a lender (agent) in a syndication deal, what are the responsibilities of the agent bank with respect to Regulation B (ECOA) compliance specifically related to adverse action notice requirements?
02/02/2020
Our loan officers pull clients credit reports and input the information in our LOS. Not all six items that make up an application for a home loan have
been provided. My question is, do we still send out a "Notice of Incompleteness" to the client if the only thing that was received in the
loan file was the credit report and the loan has been in our system for 30 days with the property marked, "TBD?"
The way I read Reg B is that you only send out the NOI once it is considered an application. So if these are not considered an application but you
obtained credit, would we not have to send some sort of documentation/NOI because the score is good enough to move forward?
12/29/2019
Do you know when the new revised Uniform Real Estate Application 1003 will be issued?
12/08/2019
Does a mortgage lender's business card require an Equal Housing Lender logo?
11/03/2019
Our commercial applicant submitted an application and we issued a (expression of interest) EOI / Term sheet. The loan officer is in
communication with them and is asking for items we require to underwrite the loan. It is taking more than 60 days to receive all the items. They are
coming in piece by piece. When are we required to send a notice of incompleteness? I was understanding that an NOIA would not be required since
the application is still not complete and we are working with the applicant, but others are saying it should be sent now.
09/15/2019
Are there any specific requirements or restrictions when it comes to lending to a non-US Citizen?
09/08/2019
For banks that provide combined ECOA-FCRA disclosures, is it standard practice to “Check the 1st Box” and provide FCRA credit score information if the decline reason is not based on the consumer report, but some other factor? (i.e. insufficient collateral, product not offered, out of lending area) Do other banks do this?
We understand that we do NOT have to “Check the 1st box” and provide credit score information if it was NOT used in making the adverse decision, but what would be the risk to provide this information in the above cases?
08/25/2019
I have a client (a lender) who orders their credit reports from "XYZ Data" and when a loan is declined, they list Equifax on their Adverse Action
Notice (with appropriate address and phone number) and they have now been told that because "XYZ Data" is considered a reseller of credit under the
FCRA 603(u) that they should also list XYZ Data (along with its name and telephone number) on the Adverse Action Notice. Is this true?
08/04/2019
What regulatory disclosure is required for refinancing a commercial mortgage loan?
07/07/2019
I know Reg B talks about a lender not discriminating when collecting on a debt. What other regulation talks about a lender fairly treating a customer during collection procedures? Fair Debt Collection Practices Act? I think a lender collecting their own debt is exempt as a "debt collector" definition.