News

Brief Overview of the Military Lending Act

Well, it’s been 2 month’s since the Military Lending Act took effect. If you’re institution hasn’t determined whether you’re ready and compliant yet, contact me because you’ve got some catching up to do. At least the credit card provisions haven’t kicked in yet, so if...

Curing Defects on Closing Disclosures

Mistakes happen. Things change. Life is unpredictable. Sometimes after closing things happen that make the CD the borrower received to be no longer accurate, or you’ll notice a mistake was made and the borrower paid a higher fee than he or she should have. Here’s how...

Understanding Intent to Proceed

Here’s a short cheat sheet on intent to proceed information: Q:           Can a borrower give intent to proceed before receiving an LE? A:            No. Section 1026.19(e)(2)(i)(A) requires the borrower to receive the disclosures before indicating an intent to...

Reporting Income on the HMDA/LAR

There can be a lot of confusion about what income or revenue to report on the HMDA/LAR. Most of this confusion can be because the income to be reported on the LAR is not always what was used to underwrite the loan. So how do you determine what to report for income on...

Rounding and Decimal Places

When should a values be rounded on the LE or CD? And what decimal place should it be rounded to? On the LE, 12 C.F.R. § 1026.37(o)(4) is the rule on rounding. The general rule is “any amount required to be disclosed by § 1026.37 [the LE] is not permitted to be rounded...