Angela Rankin

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Servicing Compliance Webinar Series: Adverse Action Requirements

It’s more than just saying “No” When are adverse action notices required? Adverse action notices requirements for denied deposit accounts Adverse action notice requirements for commercial customers Notice of incompleteness requirements How should files be documented when a customer withdraws an application. What’s the difference between a withdrawn application and an application which was approved …

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mortgage application

Clarifying the Joint Intent Requirements at Application

Joint intent exceptions are a common finding in our compliance reviews. We have found that there are misconceptions on what constitutes joint intent and how it should be documented; most of the questions come from commercial versus consumer mortgage loan officers. Many of the questions we are asked include: Isn’t the joint financial statement enough …

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LEI

Maintaining the Legal Entity Identifier (LEI): Should Partially-exempt HMDA Filers Renew?

The passing into law of the Economic Growth, Regulatory Relief, and Consumer Protection Act (EGRRCPA) provided institutions with a partial exemption of some data fields under HMDA. One of the fields in the exemption is the Universal Loan Identifier (ULI) and allows institutions to report a Non-Universal Loan Identifier (NULI). The difference between the two …

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home keyring in keyhole

HMDA Reporting for Loans Secured by Multiple Properties

We have received numerous questions about how to report multiple properties on the HMDA LAR for 2018. Quite frankly, it can be very confusing because some fields are reported on the property securing the loan and other fields are reported on the transaction. The commentary for §1003.4(a)(9) – 2 states the following: MULTIPLE PROPERTIES WITH …

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Oak Brook, IL 60523