August 2017 • RSK Compliance Solutions LLC

RSK.IQ Question of the Week 8/28/17

Posted on August 28, 2017September 26, 2017 by RSK.IQ.Staff

TRID and a Decrease in the Seller Assist

Issue/Inquiry

The Bank is financing the purchase of a home. The buyer and seller have agreed to reduce the amount of the seller assist. Does the Bank have to send a revised Loan Estimate within three days of being notified of the change, or can this just be disclosed on the Closing Disclosure?

RSK.IQ Question of the Week 8/21/17

Posted on August 21, 2017September 26, 2017 by RSK.IQ.Staff

HMDA Reporting and the Re-Application

Issue/Inquiry

The Bank closed an application file for incompleteness when the applicant failed to meet all the closing conditions. Subsequently, the applicant re-applied for the loan, as required by the Bank when a commitment expires and all the conditions had not been met. The loan was then made after all the closing conditions were fulfilled. How should this be reported on the HMDA LAR?

RSK.IQ Question of the Week 8/14/17

Posted on August 14, 2017September 26, 2017 by RSK.IQ.Staff

Regulation O and a Loan to a Director’s Spouse

Issue/Inquiry

The Bank made a loan to the spouse of a member of the Bank’s Board of Directors. The director is not a co-borrower and the income of the director was not used in the underwriting for the approval process. Is this loan subject to Regulation O?