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Relying on Previous Flood Determinations

One question we get quite often is, “can we rely on a prior flood determination”?  In short, the answer is yes but there are three requirements you must meet.  The first is that the flood determination must be on a Special Flood Hazard Determination Form.  The second...

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Reporting “Action Taken” for HMDA

While the Action Taken data field may seem pretty straightforward on the surface, it’s actually one of the more confusing requirements in HMDA.  The regulation talks about “customary commitment or closing conditions” and “underwriting or creditworthiness...

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Attention Secondary Market Lenders!

If you sell loans on the secondary market, there was a development last week you will want to be aware of.  On April 8, 2021,  Fannie Mae and Freddie Mac announced that they will only purchase loans that comply with the New General QM requirements. ...

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HMDA Small Filer

If your institution is subject to HMDA, and you made between 100 and 500 closed-end loans in each of the prior two calendar years, you're considered to be a “small filer”.  If your institution made more than 500 closed-end loans, you're a “large filer”.  While you...

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Private Flood Insurance Q&As

On March 11, 2021, the Agencies announced new proposed guidance related to flood insurance in the form of Interagency Questions and Answers (Q&As).  This included 24 new proposed Q&As just on private flood insurance. We get questions all the time on...

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BSA Compliance: Third-Party 314(a) Searches

Do you rely on a third party or your core processing vendor to conduct your 314(a) searches? If yes, are you logging into FinCEN’s Secure Information Sharing System (SISS) and downloading each 314(a) list so the third party/core processor can run it against your...

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HMDA: Loan Term vs. Line Term

If you are a HMDA bank, you know some of the data reporting requirements can be downright complicated and others just don’t seem to make sense.  One of the fields you will want to pay close attention to is the “Loan Term” field.  The term you report will differ...

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