RSK.IQ Archives • Page 47 of 122 • RSK Compliance Solutions LLC

RSK.IQ Question of the Week 3/19/18

Posted on March 19, 2018March 16, 2018 by RSK.IQ.Staff

Pre-Approvals and Pre-Qualifications under HMDA and Regulation B

Issue/Inquiry

For HMDA purposes, what is the difference between a pre-qualification and a pre-approval? Is an Adverse Action Notice necessary if the pre-qualification or pre-approval is denied? If a customer requests a pre-approval, what date should be used on the HMDA LAR for the application if the pre-approved loan does not close or is denied due to collateral, once the property has been identified?

RSK.IQ Question of the Week 3/12/18

Posted on March 12, 2018March 9, 2018 by RSK.IQ.Staff

Flood Insurance in the Absence of a RCBAP

Issue/Inquiry

The Bank has a loan secured by multiple properties, one of which is a condominium unit located in a flood zone. The borrower has obtained private flood insurance for the individual unit, but the condominium association has not obtained flood insurance. The association claims that the building is not in a flood zone. The flood determination obtained by the Bank indicates that it is in flood zone AE, a Special Flood Hazard Area.

What does the Bank need to do in order to be in compliance with the Flood Rules?

RSK.IQ Question of the Week 3/5/18

Posted on March 5, 2018March 2, 2018 by RSK.IQ.Staff

TRID and Reimbursement for Service Provider Fee

Issue/Inquiry

The Bank wonders where a tax service fee should appear on the Loan Estimate. The fee will be paid directly by the Bank to the service provider and then collected from the borrower at closing. An internally-prepared chart indicates that it should be listed in Loan Origination Fees. Is this correct?