FREE Lending Q & A

Do you have burning questions related to lending compliance?  Struggling with TRID, HMDA, Fair Lending, etc.?  If so, we’d love to have you join us on January 15, 2020, for our FREE Lending Q & A Forum where we’ll answer questions such as:

Question:  On a TRID loan, do we only disclose the fees that we will be charging the customer? 

Answer:  On the Loan Estimate, you only disclose fees that the consumer/borrower will be obligated to pay.  The Closing Disclosure should disclose all fees paid in connection with the transaction, except those services that are factored into your cost of doing business.  For example, maybe you don’t pass along an itemized cost for an appraisal, but have a higher origination fee.  In that case, the appraisal cost would not need to be itemized and disclosed.

Question:  Is a refinance of what was originally an “ag” loan HMDA-reportable?

Answer:  No. Ag loans are somewhat unique when it comes to HMDA because they are excluded both by “purpose” and “collateral”.  A loan primarily for ag purposes is not reportable, even if it meets the HMDA definition of a refinance.  Similarly, if you have a dwelling-secured loan and that dwelling is located on property that is used primarily for agricultural purposes, it is not considered a dwelling for HMDA.

All you have to do is register for the Forum on our website and then start pre-submitting your lending questions to training@bankerscompliance.com (please put “January Forum” in the subject line).  We will answer as many of your questions as we can during the allotted hour.

See you there!!

Published
2019/12/16

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