Latest Lending - Tools Topics

Defining Temporary Financing, Then & Now

07/31/2006

I'm trying to determine the definition of temporary financing. Previous guru answers (in 7/05 and 12/05) have indicated that you must look to the repayment source to determine whether a loan is temporary financing. Repayment sources may include financing from another lender or the sale of an asset. However, in the BOL Tools section, there is a HMDA chart (Consumer and Commercial HMDA Worksheet for Closed End Loans updated 3/3/06) which implies that in order to classify a loan as temporary financing the repayment source can only be outside financing. Which is the more accurate definition? For example, if a bank makes a 12 month interest-only loan to an investor to buy a 1-4 home and the investor improves it and sells it within 3 months (i.e., the sale of an asset and this was documented as the repayment source) is this a HMDA reportable loan?

Managing Pricing

01/01/2006

At PCi's 2005 CRA Colloquium, there was much discussion on pricing in the context of fairness and predatory lending. The regulators' position was clear.

Looking For Risk Management (6 Action Steps)

01/01/2006

There is no absolute for designing a risk management program.

Measuring Risk

01/01/2006

A key element of measuring risk is determining the amount and priority of risk. With compliance regulations, some risks are very difficult to manage in a way that reduces or eliminates risk.

No High Cost Mortgages?

10/01/2005

If you think you aren't making any high cost mortgages, you probably haven't done your homework. At some point, almost every lender either makes high cost loans or comes very close.

Disclosures for reverse annuity mortgage?

08/29/2005

Do any programs exist which would calculate the total cost and/or APR of a reverse annuity mortgage?

Reducing the Burden of Regulation Z: Can it be Done?

07/01/2005

Regulatory Burden is the topic of the day. Everyone is talking about it. But the real question is whether there really can be burden reduction.

BSA: New Exam Procedures

06/01/2005

The revised and uniform BSA examination procedures are scheduled to be published on June 30, 2005. While the procedures will be new, they should also be familiar.

What Determines if a Loan is HMDA-HOEPA

05/02/2005

On the new HMDA form this year, what determines how I answer the "HOEPA status" question?

Fair Lending: What Examiners are Finding (5 Action Steps)

09/01/2004

Note: special thanks to Mollie Newsome Sudhoff for research and assistance with this article.

TRID tolerance violation for omitting cost of PMI

03/09/2025

I have a processor who issued a Loan Estimate and missed the fact that the loan had a 90% LTV, and the Loan Officer did not catch it either. So, the Loan Estimate did not include PMI. Even if we redisclose it will not fix the TRID tolerance violation. I have always been told that the first month we collect at closing to pay to the PMI vendor would have to be paid by the lender to "cure" the tolerance violation, and then we continue on as normal collecting PMI escrow from the borrower monthly and passsing it on to the PMI vendor. Now someone tells me that when this happens the lender has to pay for the entire life of the PMI, because of the tolerance error. Can anyone tell me what they think and give me something to back up your thoughts?

Getting permission to pull a credit report

03/02/2025

We are reviewing our procedures when it comes to pulling credit for loans/credit cards. One question that has come up is - what is required when pulling credit? Our branch staff can take in-person and telephone applications. For in-person applications should we have the customer sign a document stating that they are authorizing us to pull credit? What should that process look like for applications taken over the phone? We are concerned that if we add a check box to the application the branch employee may click that box without discussing with the client (for both in person and over the phone applications).

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