If we have a 1-4 dwelling that is being used for a commercial purpose (day care, real estate office, doctor or dentist office etc.) and our lien will be in first position, since the loan is a commercial loan do we still need to send the upfront appraisal notice? If the property is zoned commercial or granted a zoning exception does that matter?
We have a file that started out as a Cash-out Refinance for Home Improvements. So the original purpose would be "home improvement." The appraisal came in much lower than expected. A "change of circumstance" was done to lower the loan amount, which fell short of paying-off the existing mortgage and there would not be enough funds for home improvements. The borrower withdrew the application. For HMDA reporting, should the loan purpose still be "home improvement" or should the loan purpose now be "refinance"?
Does the rate spread under HMDA Reg C apply to construction loans for residential 1-4 family?
Is it a Reg Z violation to not acknowledge a a customer's dispute letter within 30 days of receipt?
Why do our commercial lenders have to obtain an NMLSR ID number just for HMDA reporting? This is a real burden on financial institutions.