RSK.IQ.Staff, Author at RSK Compliance Solutions LLC • Page 27 of 122

RSK.IQ Question of the Week 5/13/19

Posted on May 13, 2019May 10, 2019 by RSK.IQ.Staff

The Right of Rescission When a Party in Interest is Not on the Deed

Issue/Inquiry

The Bank made a mortgage loan to refinance an existing mortgage loan from another lender. The property securing the loan, which is located in New Jersey, is the principal residence of a married couple, but only one of them is on the deed. The Bank had the spouse who is on the deed execute the note and both spouses executed the mortgage; however, only the spouse who is on the deed was provided with a Notice of Right to Cancel. If the spouse who is not on the deed has the right to rescind, what should the Bank do to correct the situation? What other disclosures should that person receive other than the Notice of Right to Cancel?

RSK.IQ Question of the Week 5/6/19

Posted on May 6, 2019May 6, 2019 by RSK.IQ.Staff

HMDA – New Loan but Different Borrower

Issue/Inquiry

A mortgage loan that was originally in an individual’s name is being satisfied by a loan in the name of a business entity. Would the way in which the loan was reported on the HMDA LAR be affected if the name changed before the closing of the new loan or at closing?

RSK.IQ Question of the Week 4/29/19

Posted on April 29, 2019April 26, 2019 by RSK.IQ.Staff

Fair Lending and Disparate Treatment

Issue/Inquiry

The Bank declined two applications for unsecured personal loans on the basis of “lack of assets”. Does this indicate disparate treatment?