Bankers Blog
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Force Placed Flood Insurance Article Updated
As many of you know, the Free Lending Tools page on our website has very useful tools and resources to help you on your lending compliance journey. One of those resources is our “Flood Insurance Force Placement” article. This article has been around for...
Beneficial Ownership Certification – current ownership, or the soon-to-be ownership?
Question: A legal entity currently owned by a husband and soon-to-be ex-wife wants a refinance loan for the husband to buy out the ex-wife’s interest in the legal entity. Should the Beneficial Ownership Certification be completed according to the current ownership,...
The TRID “Good Faith” Standard
TRID says that when you issue a document like a Loan Estimate, or a revised Loan Estimate, or a closing Disclosure, or a revised Closing Disclosure, the information that's contained within has to be based on the best information available. That's the good faith...
Private Flood Insurance Checklist
Back in August, we added sample Private Flood Insurance Procedures to the free Lending Tools page of our website. These sample procedures were designed to give you a starting point or framework to help you develop procedures for your institution. We...
HMDA: The Income Field
When it comes to auditing HMDA, one of the most common errors we see cited by examiners and auditors is the income field. It is confusing. What numbers should the loan officer use? Is it what the applicants put on their application, is it taken from a tax...
CFPB Issues HMDA Final Rule
The CFPB issued a Final Rule that addresses portions of their May 2019 Notice of Proposed Rulemaking. That particular Proposal is not to be confused with the Advanced Notice of Proposed Rulemaking that was also issued in May 2019. Both have comment deadlines of...
Ask the Experts!
If you’ve never joined us for our Forum, now is the time to check it out! Our Forum is a FREE, one-hour webinar that we host four times a year. We cover a variety of topics and allow you to pre-submit questions to ask our experts. We present material on a topic...
Forgetting a Fee on the Loan Estimate
Question: What happens when you forget a fee on the Loan Estimate and it's added to the Closing Disclosure, but it is in an Unlimited Tolerance Category? Answer: If you miss disclosing the fee on the Loan Estimate, you will be in...
HMDA: We’ve Got You Covered!
2018 was the first year of reporting under the new HMDA data requirements. We’d be lying if we said the transition was easy. Far from it! To add to the difficultly, there were several little tweaks along the way. We are over halfway through year two of...
HMDA Income
Question: If a commercial officer uses net income to underwrite the loan, should we report Net Income instead of Gross Income on the HMDA-LAR? Answer: While the regulation specifies “gross” annual income, it goes on to say, that is relied on...