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First, it should be an attribute on your post-closing loan checklist to assure that it’s obtained when required. This assures individual loan compliance.
As an auditor, we only look for MLA compliance when auditing consumer loans (doesn’t apply to mortgages). We sample all types of consumer loans/lines (vehicle, deposit secured, unsecured, other secured, etc.) and look for MLA compliance as one of our checklist attributes. It can be hit or miss (as was the case with vehicle secured loans). So far, we’ve not heard any concerns with this methodology.
Understood. But can they elect to report as a CD loan because of the FIL even though it’s less than $1 Million?
It was a cash-out refi; old mortgage satisfied and replaced. Not temporary financing.
So, I think you’re suggesting to treat it as a refinance rather than a purchase?
But if the parents had no prior mortgage, how would you treat it?
Bob Baffert’s horses usually do well – I’m going with the front-runner #6 – Bodemeister. He’s already won a million in Arkansas derby. Only 4 races but 2 wins and 2 seconds. And a name like “Bodemeister” sounds unforgettable.
I’m from Lancaster County PA. Generally, mutual aid insurance is available by each Amish or Old Order Mennonite “district” and the local Bishop should be able to provide a letter that any losses will be covered by the district. But in order to accept this coverage, you will first probably need to define lending to the Amish (or other religious sect) as a “Special Purpose Credit” in your loan program and spell out what you will accept in lieu of hazard insurance. I agree with Jack that they cannot be exempted from FEMA requirements for flood insurance.
Another issue commonly encountered is customer identification for the Amish/Old Order Mennonites. This is possible. Though they don’t have driver’s licenses (after they’ve joined the church around age 21; males can/do have DLs between 16 and that age while they are “sowing their wild oats”), they can get state-issued ID cards from the Dept of Transportation. Though they don’t accept government programs, they still work, vote, will file income taxes, and will have a social security card. Plus many of them work off the farm and ID/SSN are required in those circumstances. Or your program can define alternate identification such as a copy of a tax bill (ex: real estate ownership), utilities (they can use cell phones but only in the barn!; they do have propane gas service), or other services (dry goods store, farm supply store, etc.) where they get bills that can provide address, account number, date of issuance. As nondocumentary verification, your program could define a letter of identification from their local Bishop that they are a member of the local district. The most difficult issue is identifying Amish/Old Order Mennonite women – they are generally not allowed to own land or establish services. In this regard, your policy will need to provide for a Birth Certificate and Social Security Card because that’s about all they will have.
Hope this helps 🙂 !
