Do you have burning questions related to lending compliance? Struggling with TRID, HMDA, Fair Lending, etc.? If so, we’d love to have you join us on January 26, 2021, for our FREE Lending Q & A Forum where we’ll answer questions such as:
Question: Are we required to document all the different ways an applicant can provide intent to proceed?
Answer: We do believe it’s a good idea to formalize how you will accept the intent to proceed to help ensure consistency among your lenders. The regulation allows applicants to give you the intent to proceed in any way they choose, unless you require a certain method. If you don’t limit the ways someone can give you the intent to proceed, we would recommend your procedures simply reflect that applicants can provide intent to proceed in any way they choose.
Question: When we match a rate from a competing institution, what kind of documentation are we required to keep?
Answer: There really aren’t any guidelines that address this specifically. At a minimum, we believe a loan officer should simply document the reason(s) for any exceptions and/or pricing decisions that were made/given. More specifically, spell out very clearly “why” the rate given doesn’t match the rate sheet or loan policy. Lenders should be sure to check with their compliance officer/management to ensure any institution-specific requirements.
Register for the Forum on our website and then start pre-submitting your lending questions to training@bankerscompliance.com (please put “January Forum” in the subject line). We will answer as many of your questions as we can during the allotted hour.
See you there!!
Published
2020/12/28
