Bankers Blog
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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...
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...
HMDA Question: Collecting Demographic Information
We received the following HMDA question recently. It’s one we get asked a lot, so we thought we would share. Question: If an application is filled out via internet, telephone, or mail, and the applicant does not provide information regarding ethnicity, race, or...
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. ...
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...
Flexibility Rescinded & Warning Shots Fired: Are You Prepared?
We recently alerted you to the fact that the CFPB rescinded several temporary policy statements issued in 2020 which provided flexibility to financial institutions in response to the COVID-19 pandemic. That was a warning shot to the industry that the CFPB...
CFPB Proposes Mortgage Servicing Changes and FDCPA Delay
The CFPB is continuing their efforts to minimize the number of foreclosures resulting from the COVID-19 Pandemic. As such, it recently proposed changes to the mortgage servicing rules which set out to give …both servicers and borrowers…tools and time…to prevent...
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...
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...
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...