[jholzknecht]

1. from FNB Bank to Everyone: Will denial reasons still be optional?

2. from Chris to Everyone: I think the proposals indicate that denial reasons are mandatory now when these proposed changes go through?

ANSWER: Section 1003.4(c)(1) currently permits optional reporting of the reasons for denial of a loan application. However, certain financial institutions supervised by the Office of the Comptroller of the Currency (OCC) and the Federal Deposit Insurance Corporation (FDIC) are required by those agencies to report denial reasons on their HMDA loan application registers. The CFPB is proposing to require all financial institutions subject to HMDA reporting to report the reasons for denial of a loan application.

3. from FNB Bank to Everyone: With regard to LTV will there be standards for concluding value?
ANSWER: Section 1003.4(a)(24) requires collection of the ratio of the total amount of debt secured by the property to the value of the property, determined as follows:
(i) For a covered loan that is a home-equity line of credit, by dividing the sum of the unpaid principal balance of the first mortgage, the full amount of any home-equity line of credit (whether drawn or undrawn), and the balance of any other subordinate financing by the property value identified in paragraph (a)(28) of this section;
(ii) For a covered loan that is not a home-equity line of credit, by dividing the combined unpaid principal balance amounts of the first and all subordinate mortgages, excluding undrawn home-equity lines of credit amounts, by the property value identified in paragraph (a)(28) of this section.

4. Hi Jack, where can we see an example of what the MISMO format looks like?
ANSWER: For a recent blog article with information on MISMO click here. For MISMOs home page click here. For the actual specifications click here, a login will be required.

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