During a recent Regulation E training event, the class and I discussed the Regulation E Section 1005.11 “Procedures for resolving errors” and there, as always, was very active discussion of what a bank may request, but not require. I brought up the prohibition against requiring police reports as a requirement for the bank to either begin the investigation provision or to provide provisional credit and there were a number of questions. Many banks have in […]
Month: August 2016
MLA QUESTIONS AND ANSWERS
On August 26 the Department of Defense (DOD) published 19 questions and answers concerning the requirements of the Military Lending Act and its Part 232. Many questions have swirled around the provisions of Part 232 for some now. Some of the questions are clearly answered in the document; other answers are quite fuzzy. The questions and answers represent official interpretations of the DOD on issues related to 32 CFR part 232. The interpretations are effective […]
NEW FLOOD HAZARD DETERMINATION FORM
On July 27, 2016 FEMA made available on its website an updated Flood Hazard Determination Form (SFHDF). The SFHDF is required for all federally backed loans and is used by lenders to determine the flood risk for their building loans. The previous form which expired on May 30, 2015 can continue to be used during the phase in period of the new form. The phase-in period has not been detailed at this time. The new form […]
FANNIE RELEASES REVISED 1003
Fannie Mae released Tuesday, August 23rd, the publication of the redesigned Uniform Residential Loan Application (URLA) – Fannie Mae Form 1003. The newly redesigned URLA is a 7-page interactive pdf document that contains drop-down menus as well as totals for the calculation of certain sections. In addition, the following components are included: borrower information, additional borrower, unmarried addendum, lender loan information, and a continuation sheet. Instructions are included to assist in the completion of the […]
FINCEN BENEFICIAL OWNERSHIP Q’S AND A’S.
On July 19, 2016, FinCEN issued FIN-2016-G003 with the following subject line: Frequently Asked Questions Regarding Customer Due Diligence Requirements for Financial Institutions (“FAQ”) FinCEN’s stated purpose in issuing these FAQs was to assist covered financial institutions in understanding the scope of the Customer Due Diligence (CDD) requirements for financial institutions which were published in the Federal Register on May 11, 2016 and which become fully effective on May 11, 2018. The May, 2016 CDD […]