With the release of Fannie Mae's Day 1 Certainty, we are looking into allowing Property Inspection Waivers. If we exercise this option and the loan amount is over $250,000, can we prepare a written valuation to be compliant with ECOA or do we have to order a full appraisal since it is greater than $250,000? This would be in the State of Wyoming.
I received a private flood policy for a commercial loan with 24 structures located in a flood zone. The coverage amount is over $3 million more than what is required. However, based on the definition of "Private Flood Insurance," the policy does not meet all of the requirements. Are there any best practices or additional guidance besides the proposed rules that are not finalized? We are a member in this syndicated deal and the agent bank is willing to accept the risk of not having all of the required items. Given our bank must perform our due diligence separately, I am not comfortable accepting the policy as is and am looking for guidance on something I may be missing.
When a borrower is deceased, family members continue to make payment and the account has an escrow account: 1. Is the bank still obligated to continue paying taxes and insurance from the escrow account? 2. If the loan has PMI does the company need to be notified? If the loan does not have an escrow account: 1. If the loan payments are still being paid by a family member and the insurance is being paid but left in the deceased person's name, what avenue should the bank take?
If escrowed, are taxes and insurance included in the mortgage payment amount when calculating the debt-to-income DTI ratio on a new consumer loan?
I am looking for regulation that allows a creditor to obtain credit scores for existing customers to use for monitoring and tracking purposes, or restricts such purpose. For example, quarterly tracking of a customer's credit score to detect any deterioration that may also then be used for adverse action on a consumer line of credit such as suspending the line. Another example is to track improvement of credit scores where the creditor has granted consumer a loan for the purposes of credit repair or establishing a credit history.