11/01/2002
The penultimate session at PCi's CRA and Fair Lending Colloquium was a discussion and debate on payday lending.
10/28/2002
We are still struggling with HOEPA. None of us wants to originate HOEPA loans but if we do, we have the disclosures ready to issue the borrower (3 days prior). Is anyone aware of how many or what percentage of a bank's portfolio can be identified as HOEPA loans before the bank is viewed unfavorably by the regulators and/or Community Groups? Has a benchmark been published or discussed somewhere? Any ideas?
10/21/2002
If we approve a customer for a loan and they want a copy of their credit report can we give it to them?
10/21/2002
Is it necessary to report our commercial and agricultural loans to the credit bureau? If not necessary, is it recommended?
10/07/2002
When an application is taken and there is a co-maker and the co-maker gives a spouse as source of other income, can the bank pull the credit bureau of the spouse? The source of other income is not on the note and basically has no benefit from the proceeds. The applicant is the son, the co-applicant is the mother and the mother has put her husband down as other source of income. The source is not a user.
09/16/2002
Bankers Compliance Consulting Real Estate Loan Matrix. I found on this web site indicates that a closed end home equity loan is not HMDA reportable. I would like to know the reason the author made that decision. I find the reg excludes open end lines of credit only...
08/12/2002
For a consumer-purpose, revolving line of credit, are we still required to disclose the same information normally found in the fed box on regular notes - APR, Amt Financed, etc? If we have a non-consumer that is getting a loan to purchase or build a single family residence for resale, do we include them on our HMDA report?
06/10/2002
by Mary Beth Guard
Question: We have a form that we are using but I can't remember what allowed it.
05/20/2002
Are we required to obtain a W-9 on our loan customers. Our data processing company issues a TIN missing or not certified exception on a number of our loan customers. I'm unclear on how to deal with these exceptions.
05/06/2002
We are confused as to what is considered a prequalification and what is an application. According to your definition it's a prequalification if a specific property is not identified. We have a situation where a borrower came in and got prequalified without a specific property in mind. At this point we are classifying the file as a prequalification. Several days later he calls and says he has found a property and is signing the purchase agreement that day. Our loan officer does not send out disclosures until a week later when she gets the purchase agreement. Should her three days have started when he told her he had found a property and was signing the purchase agreement? Our loan officer is saying that the borrower did not state the specific address (the loan officer did not ask for it either). Therefore our loan officer said it was still a prequalification until she received the purchase agreement. Is the loan officer correct? If it is not considered an application until we have the specific address what obligation do we have to ask for the address? This loan officer also stated that she never does the disclosures until she has a purchase agreement. Any information you have on a prequalification versus application and when we are required to send disclosures would be great. We argue about this all the time!