Calendar of Events

Compliance Rules for Commercial Loans Secured by Real Estate

02/15/2018, 10:00 AM to Noon

No location provided

Amy Davis adavis@msbankers.com 601-948-6366

Description:

Compliance Rules for Commercial Loans Secured by Real Estate
 

Presented by Susan Costonis
Thursday, February 15th, 2018
10:00 am - 12:00 pm CT
 

Covered Topics

  • What factors determine if the application is for business purpose or consumer purpose?
  • What are the compliance requirements when real estate is taken as collateral?
  • Review of the required disclosure for the "Right to Receive a Copy of Appraisal." Who gets the notice and what are the timing rules? This DOES apply to 1st lien loans of 1-4 units, regardless of purpose; there is no "business-purpose" exception.
  • What are some common compliance violations in the commercial loan area when real estate has been taken as collateral?
  • Review of the HMDA requirements and review of the changes to business purpose loans for the extensive HMDA rules that became effective January 1, 2018.
  • Coverage issues – Which COMMERCIAL applications are covered loans that require data to be collected at the time of application? What types of dwellings are included? Best practices for documenting that applications for agricultural purpose are EXEMPT for HMDA reporting in 2018. However, other compliance requirements still apply for real estate secured agricultural loans!
  • What data will be reported? What data will be excluded for business applications? Business purpose loans have many fields that are “not applicable”.
  • Suggestions for potential problems with collecting, reporting, and validating the data fields for “applicant” and applications in these required fields and understanding when they may NOT be reported:
    • Age for applicants who are “natural persons”, for example a sole proprietor
    • Income – when is reporting required?
    • Reasons for denial – potential problem area for commercial applications
    • Application date
    • Ethnicity, race and sex
      • Disaggregation of ethnicity and race
  • Flood insurance violations can be costly. What are some of the unique challenges with commercial buildings and collateral?
  • There are four "trip wire" events for flood insurance. Learn about the revised rules for "detached structures on residential property", this can include business purpose loans.

    BONUS TOOLS
  • Matrix of 28 loan types; required disclosures for both consumer and commercial loans with explanations about real estate secured loans.
  • Checklists that outline which compliance regulations apply to commercial credit and the exemptions for certain rules.
  • HMDA flowchart and tips for 2018 reporting activity
  • Flood insurance resources
Register here