[Ginji244]

A follow up question….if flood insurance is cancelled, we send out the required 45 day notification and receive proof of new coverage (via a standard flood insurance application) and proof of payment, does this fall under the definition of making, increasing, extending or renewing a loan. The insurance company has a 30-day waiting period on the application. Do we need to force place in the interim, if there is a waiting period? Thank you.

[Ginji244]

Thank you Robin, I appreciate the response and especially the link.

[Ginji244]

Thank you Robin, no these are better described as hard money lender loans to consumers to purchase their homestead. I am currently doing a full review like I would on a mortgage loan that our bank is financing. It is very time consuming, frequently incorrect and very frustrating.

[Ginji244]

I would like to add to this list of questions. I’m still a little confused by closed end loans with a consumer purpose secured by commercial property. For example: a consumer customer applies for a loan to purchase a second home but plans to use their commercial building that they own free and clear as collateral. It appears to me that since this is a closed-end consumer credit transaction secured by real property we would have to provide the applicant(s) with a Loan Estimate. Right?
I for one am so happy the effective date was pushed back. I’m still trying to finish training our loan team so I want to make sure all the bases are covered…….as much as possible! Thank you.

[Ginji244]

We send an adverse action notice to all commercial applicants. My question is, if one of the reasons for denial is the guarantors poor credit, do we include the credit score noitce on the AAN that we send to the commercial applicant?

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