06/12/2006
We have discovered that a few variable simple interest loans have been printed on a simple interest note disclosure and security agreement instead of a variable simple interest note disclosure and security agreement. We have considered converting these to fixed rate loans rather than redisclose. Any suggestions?
05/15/2006
We are considering making loans via the internet. I know CIP and internet security need to be arduous. What other considerations and compliance issues are there?
04/24/2006
My question deals with the definition of the term abundance of caution. I have recently read "to qualify under the abundance of caution definition, you would have to make the loan under the same terms and condition as if the borrower did not offer the real estate as collateral." However, in some FDIC material I have read the following: "abundance of caution, e.g., the institution takes a blanket lien on all or substantially as of the assets of the borrower, and the value of the real property is low relative to the aggregate value of all other collateral." These two seem to be in conflict. Can any of you help me get a handle on what exactly is meant by this term? If possible cite your source.
04/03/2006
For residential mortgages, are there any occasions when a Notice of Right to Cancel is not required (on purchases and non-owner occupied properties)?
01/23/2006
We recently completed a MSB risk assessment on deposit customers. However, we are now wondering if we should have included business customers who only have a loan relationship with the bank. Should we have included these customers as well?
01/01/2006
The financial regulatory agencies have issued joint guidance on nontraditional mortgage products.
11/21/2005
Is the 314a request the same thing as the OFAC list? I was told they were 2 separate things and I was also told that the 314a requests are the new names that will be included on the OFAC list. Could you please tell me which one is correct?
11/01/2005
10/01/2005
10/01/2005
The 2004 HMDA data is finally out and the numbers show what we expected and feared: Black Americans fare less well in the mortgage market than non-Hispanic whites. Now what?