Oct 12, 2011 FIC Alliance â Week 11 Requests for Prequalification
Oct 12, 2011
FIC Alliance – Week 11
Requests for Prequalification Most Lenders Do NOT Perform PREQUALIFICATIONS by definition even though they may refer to their process as PREQUALIFICATION During the period when consumers are loan shopping, often times lenders are faced with difficulty in determining whether disclosure obligations to consumers have been triggered and determining what point in the process should they be providing disclosures. Sometimes, what begins with a mortgage lender providing information to a consumer to shop for a loan, can turn into an evaluation of creditworthiness and possibly an application for credit. It is important to realize that several of the regulations may apply during the inquiry stage, before application has been made by the consumer. With prequalification, (meaning a consumer may approach a lender not necessarily ready to seek a loan, but may wish to determine the price of a home they can afford) in many cases the consumer has not yet identified a specific property.
ECOA/Reg B & HMDA/Reg C definition of a Prequalification A prequalification request is a request by a prospective loan applicant (OTHER THAN A REQUEST FOR PREAPPROVAL) for a preliminary determination on whether the prospective applicant would likely qualify for credit under the institution’s standards, or for a determination on the amount of credit for which the prospective applicant would likely qualify. A creditor may treat a request as an inquiry if the creditor evaluates specific information about the consumer and tells the consumer the loan amount, rate and other terms of credit the consumer could qualify for under various loan programs, explaining the process the consumer must follow to submit a mortgage application and the information the creditor will analyze in reaching a credit decision.
ECOA/Reg B - Examples of inquiries that are not Applications i. A consumer calls to ask about loan terms and an employee explains the creditor’s basic loan terms, such as interest rates, loan-to-value ratio, and debt-toincome ratio. ii. A consumer asks about terms for a loan to purchase a home and tells the loan officer her income and intended down payment, but the loan officer only explains the creditor’s loan-to-value ratio policy and other basic lending policies, without telling the consumer whether she qualifies for the loan. iii. A consumer calls to ask about terms for a loan to purchase vacant land and states his income and the sales price of the property to be financed, and asks whether he qualifies for a loan; the employee responds by describing the general lending policies, explaining that he would need to look at all of the consumer’s qualifications before making a decision, and offering to send an application form to the consumer.
HUD’s Recommendation In the newly revised HUD’s Settlement Costs Booklet “Shopping for Your Home Loan” HUD recommends homeowner’s self assess their affordability by using this worksheet located in the Appendix on page 36 “Determining What You Can Afford.”
Homebuyers can use this worksheet to calculate their monthly income and expenses to determine the amount left over every month to pay for house related expenses such as a monthly mortgage payment, property taxes and homeowner’s insurance. There is also a mortgage calculator that homeowners may wish to use which can be found at: http://ginniemae.gov/2_prequal/intro_questions.asp?Section=YPTH.
FIC Regulatory Education Alliance / Copyright ©FIC Conferences, Inc. – Oct 12, 2011 – Week 11 Page 2
Lenders should monitor the consistency with their own policies and procedures that have been established as to how prequalification should occur, when preliminary disclosure obligations to the consumer have been triggered, and at what point in the process they are actually providing the disclosures. At the present time, the federal regulations, including RESPA, do not uniformly provide a clear bright line for prequalification inquiry versus an application for credit.
Lenders have designed worksheets for the Prequalification Process Many mortgage lenders offer formal or informal information to prospective mortgage loan applicants prior to the submission of a written loan application. Such activities may include: • Formal prequalification programs, in which lenders apply basic underwriting standards (such as housing and debt ratios) to the prospective applicant’s situation. Frequently lenders provide worksheets indicating the maximum loan for which borrowers would qualify, usually subject to a satisfactory property appraisal and further verification of income, employment and credit history. Some prequalification programs even provide a preliminary evaluation of credit history. • Home buyers’ forums and seminars, in which a variety of real estate experts (lenders, real estate brokers, lawyers, appraisers, etc.) provide information about the home buying process and what may be required at each step. • Informal or undocumented conversations between prospective applicants and lender representatives, in which potential applicants may be encouraged, counseled or coached as to their qualifications and what information they might need to provide in order to strengthen their applications. These and other similar activities allow consumers to shop more effectively for a property that they can afford. Such programs can also be a key element in the penetration of low and moderate income markets and the success of first time home buyer programs. Prequalification advice and assistance can also be an important part of a lender’s community reinvestment strategy. Lenders should note, however, that prequalification services must be provided equitably to all customers and that none of the criteria used to prequalify or advise the potential applicant may, explicitly or in effect, include illegal discriminatory factors.
FIC Regulatory Education Alliance / Copyright ©FIC Conferences, Inc. – Oct 12, 2011 – Week 11 Page 3
When consumer is told they DO NOT qualify… If after evaluation of the information, the creditor decides that it will not approve the request and communicates this to the consumer, a creditor has treated a prequalification request as an Application, and is subject to Adverse Action. Regulation C does not require an institution to report prequalification requests on the HMDA-LAR, even though these requests may constitute applications under Regulation B for purposes of adverse action notices. Whether a creditor must provide a notice of action taken for a prequalification request depends on the creditor's response to the request. For instance, a creditor may treat a request as an inquiry if the creditor provides general information such as loan terms and the maximum amount a consumer could borrow under various loan programs, explaining the process the consumer must follow to submit a mortgage application and the information the creditor will analyze in reaching a credit decision. On the other hand, a creditor has treated a request as an application, and is subject to the adverse-action notification requirements if, after evaluating the information, the creditor decides that it will not approve the request and communicates this to the consumer. For example, in reviewing a request for prequalification, a creditor tells the consumer that it would not approve an application for a mortgage because of a bankruptcy in a consumer's record, the creditor has denied an application for credit.
Prequalifications must be contrasted with “What is an APPLICATION?” Understanding the distinction between an “inquiry” and an “application” is important for compliance with Regulation B because several requirements apply only to applications (not inquiries). Regulation B defines a loan application as: … an oral or written request for an extension of credit that is made in accordance with the procedures established by a creditor for the type of credit requested. The Federal Reserve’s staff interpretations of Regulation B further clarify that the phrase “procedures established”: … refers to the actual practices followed by a creditor for making credit decisions as well as its stated application procedures. For example, if a creditor’s stated policy is to require all applications to be in writing on the creditor’s application form, but the creditor also makes credit decisions based on oral requests, the creditor’s established procedures are to accept both oral and written applications.
FIC Regulatory Education Alliance / Copyright ©FIC Conferences, Inc. – Oct 12, 2011 – Week 11 Page 4
In other words, in some circumstances, informal inquiries, whether verbal or in writing, must be treated as an application pursuant to Regulation B. When a lender verbally disqualifies a potential borrower, even on a legitimate underwriting basis, the lender, according to Regulation B, is treating an inquiry as an application. Therefore, if enough information has been collected to deny a loan, and a denial has been communicated to the applicant, this interaction between a lender and prospective borrower is an “application” for the purposes of Regulation B. This is true, regardless of the amount of information collected by the lender, lender application procedures, fees paid to the lender, whether the prospective applicant has identified a specific property or loan amount, or whether the communication is written or verbal. These provisions affect mortgage prequalifications because, in situations where a prequalification meets the regulation B definition of an “application,” a creditor will need to provide a written adverse action notice. This is true regardless of where the applicant is in the prequalification process or how much (or little) information has been collected by the lender. In contrast to declined applications, as long as prospective applicants are being encouraged to proceed, lenders have reasonable discretion in defining what constitutes an application. The Regulation B staff interpretations indicate that “a creditor has the latitude under the regulation to establish its own application process and to decide the type and amount of information it will require from credit applicants.”
When is an Adverse Action Notice Required? ECOA requires the creation of a paper trail for all inquiries, including prequalifications, that meet the Regulation B definition of an “application.” Specifically, for all applications, whether written or verbal, Regulation B provides that: … a creditor shall notify an applicant of action taken within: (i) 30 days after receiving a completed application concerning the creditor’s approval of, counteroffer to, or adverse action on the application; (ii) 30 days after taking adverse action on an incomplete application, unless a notice of incompleteness is provided; (iii) 30 days after taking adverse action on an existing account; or (iv) 90 days after notifying the applicant of a counteroffer if the applicant does not expressly accept the credit offered.
Notice of Adverse Action must be in writing & must include the following: a. Name and address of the creditor; b. A statement of the action taken;
FIC Regulatory Education Alliance / Copyright ©FIC Conferences, Inc. – Oct 12, 2011 – Week 11 Page 5
c. A statement of the specific reasons for the actions or a disclosure of the applicant's right to receive the reasons within 30 calendar days if the statement is requested within 60 days of the financial institution's notification; - These reasons should be the principal reasons for taking adverse actions; i.e., statements that the adverse action was based on the financial institution's internal standards or policies are insufficient. - Disclosure of more than 4 reasons is not likely to be helpful to the applicant and therefore should be discouraged. - Statements that the adverse action was based on the applicant's failing to achieve a qualifying score on the financial institution's credit scoring system are insufficient.
d. Name and address of the federal agency administering compliance with respect to the creditor. e. Name, address and phone number of a consumer reporting agency from which information was received which contributed to the financial institution's decision to take adverse action. If information from more than one agency was used in this manner, each agency's information should be similarly disclosed. (If the reporting agency is national, a toll free number should be provided.) f. A statement that the consumer reporting agency was not responsible for the credit decision. g. A notice of the consumer’s right to a free copy of the credit report if requested within 60 days of receiving adverse action notice and a statement of the consumer’s right to dispute inaccurate information. h. Name, address and phone number of an outside source other than a consumer reporting agency (another financial institution or creditor) if information from such a source contributed to the financial institution's decision to take adverse action.
Record Retention Requirements A creditor must retain the required documents for a period of 25 months. In some cases, specific regulators may require retention since the last exam. In any case in which there are court proceedings, all records must be maintained until this is complete. The following should be retained: 1. the Application (and any attachments thereto) 2. the Notification of Action Taken 3. the Statement of Specific Reasons for Adverse Action 4. any Written Statement Submitted by the Applicant Alleging a Violation of this Act of this Regulation
FIC Regulatory Education Alliance / Copyright ©FIC Conferences, Inc. – Oct 12, 2011 – Week 11 Page 6
It is essential to remember, however, that the exemption from HMDA reporting requirements does not extend to Regulation B requirements regarding adverse actions or written applications. The Regulation C staff commentary notes that: … Regulation C does not require an institution to report prequalification requests on the HMDA-LAR, even though these requests may constitute applications under Regulation B. Lenders offer a wide variety of programs and services to assist customers in selecting and qualifying for various mortgage loan options. ECOA, HMDA and FHA and their implementing regulations should all be considered in designing and managing prequalification programs and services. In particular, lenders should be aware that prequalifications are subject to ECOA and FHA prohibitions from making oral or written statements that would discourage an applicant from pursuing an application based on any of the prohibited basis. As a precautionary measure and management tool, lenders may want to consider monitoring adverse action notices and application files to prevent, detect, monitor, and correct illegal discrimination. The time between the initial contact with the prospective borrower and the submission of a formal written application (the stage where prequalifications occur) is a stage where discrimination, intentional or not, is difficult to monitor, detect and prevent. Many lenders have developed second review programs in which applications that are likely to be denied are reviewed to ensure that all possible avenues for approval have been explored prior to formal denial. Prequalification “rejections” should be candidates for any internal program that takes a second look at rejected applications. Every lender should make sure that those verbal and prequalification denials are given the same consideration as more formal applications. Kimberly Lundquist FIC Conferences, Inc. 1150 N Loop 1604 W Suite 108-603 San Antonio, TX 78248
Tel 210.493.1761 Fax 210.493.9659 [email protected] www.ficconferences.com
FIC Regulatory Education Alliance / Copyright ©FIC Conferences, Inc. – Oct 12, 2011 – Week 11 Page 7
Supplement I Part 202 – Regulation B - Official Staff Interpretations Following is an official staff interpretation of Regulation B (12 CFR part 202) issued under authority delegated by the Federal Reserve Board to officials in the Division of Consumer and Community Affairs. References are to sections of the regulation or the Equal Credit Opportunity Act (15 U.S.C. 1601 et seq.). 202.2(f) Application 202.9(a) Notification of Action Taken http://www.fdic.gov/regulations/laws/rules/6500-3000.html#fdic6500supplementitopart202
HMDA – Official Staff Commentary on Regulation C SECTION 203.2—Definitions 2(b) Application http://www.ffiec.gov/hmda/pdf/regulationc2004.pdf
FDIC – Home Mortgage Disclosure Act http://www.fdic.gov/regulations/compliance/manual/pdf/V-9.1.pdf
NCUA – Home Mortgage Disclosure Act http://www.ncua.gov/GenInfo/GuidesManuals/HMDA_reporting/HMDAreporting.aspx
FIC Regulatory Education Alliance / Copyright ©FIC Conferences, Inc. – Oct 12, 2011 – Week 11 Page 8
FIC Alliance – Week 11
Requests for Prequalification Most Lenders Do NOT Perform PREQUALIFICATIONS by definition even though they may refer to their process as PREQUALIFICATION During the period when consumers are loan shopping, often times lenders are faced with difficulty in determining whether disclosure obligations to consumers have been triggered and determining what point in the process should they be providing disclosures. Sometimes, what begins with a mortgage lender providing information to a consumer to shop for a loan, can turn into an evaluation of creditworthiness and possibly an application for credit. It is important to realize that several of the regulations may apply during the inquiry stage, before application has been made by the consumer. With prequalification, (meaning a consumer may approach a lender not necessarily ready to seek a loan, but may wish to determine the price of a home they can afford) in many cases the consumer has not yet identified a specific property.
ECOA/Reg B & HMDA/Reg C definition of a Prequalification A prequalification request is a request by a prospective loan applicant (OTHER THAN A REQUEST FOR PREAPPROVAL) for a preliminary determination on whether the prospective applicant would likely qualify for credit under the institution’s standards, or for a determination on the amount of credit for which the prospective applicant would likely qualify. A creditor may treat a request as an inquiry if the creditor evaluates specific information about the consumer and tells the consumer the loan amount, rate and other terms of credit the consumer could qualify for under various loan programs, explaining the process the consumer must follow to submit a mortgage application and the information the creditor will analyze in reaching a credit decision.
ECOA/Reg B - Examples of inquiries that are not Applications i. A consumer calls to ask about loan terms and an employee explains the creditor’s basic loan terms, such as interest rates, loan-to-value ratio, and debt-toincome ratio. ii. A consumer asks about terms for a loan to purchase a home and tells the loan officer her income and intended down payment, but the loan officer only explains the creditor’s loan-to-value ratio policy and other basic lending policies, without telling the consumer whether she qualifies for the loan. iii. A consumer calls to ask about terms for a loan to purchase vacant land and states his income and the sales price of the property to be financed, and asks whether he qualifies for a loan; the employee responds by describing the general lending policies, explaining that he would need to look at all of the consumer’s qualifications before making a decision, and offering to send an application form to the consumer.
HUD’s Recommendation In the newly revised HUD’s Settlement Costs Booklet “Shopping for Your Home Loan” HUD recommends homeowner’s self assess their affordability by using this worksheet located in the Appendix on page 36 “Determining What You Can Afford.”
Homebuyers can use this worksheet to calculate their monthly income and expenses to determine the amount left over every month to pay for house related expenses such as a monthly mortgage payment, property taxes and homeowner’s insurance. There is also a mortgage calculator that homeowners may wish to use which can be found at: http://ginniemae.gov/2_prequal/intro_questions.asp?Section=YPTH.
FIC Regulatory Education Alliance / Copyright ©FIC Conferences, Inc. – Oct 12, 2011 – Week 11 Page 2
Lenders should monitor the consistency with their own policies and procedures that have been established as to how prequalification should occur, when preliminary disclosure obligations to the consumer have been triggered, and at what point in the process they are actually providing the disclosures. At the present time, the federal regulations, including RESPA, do not uniformly provide a clear bright line for prequalification inquiry versus an application for credit.
Lenders have designed worksheets for the Prequalification Process Many mortgage lenders offer formal or informal information to prospective mortgage loan applicants prior to the submission of a written loan application. Such activities may include: • Formal prequalification programs, in which lenders apply basic underwriting standards (such as housing and debt ratios) to the prospective applicant’s situation. Frequently lenders provide worksheets indicating the maximum loan for which borrowers would qualify, usually subject to a satisfactory property appraisal and further verification of income, employment and credit history. Some prequalification programs even provide a preliminary evaluation of credit history. • Home buyers’ forums and seminars, in which a variety of real estate experts (lenders, real estate brokers, lawyers, appraisers, etc.) provide information about the home buying process and what may be required at each step. • Informal or undocumented conversations between prospective applicants and lender representatives, in which potential applicants may be encouraged, counseled or coached as to their qualifications and what information they might need to provide in order to strengthen their applications. These and other similar activities allow consumers to shop more effectively for a property that they can afford. Such programs can also be a key element in the penetration of low and moderate income markets and the success of first time home buyer programs. Prequalification advice and assistance can also be an important part of a lender’s community reinvestment strategy. Lenders should note, however, that prequalification services must be provided equitably to all customers and that none of the criteria used to prequalify or advise the potential applicant may, explicitly or in effect, include illegal discriminatory factors.
FIC Regulatory Education Alliance / Copyright ©FIC Conferences, Inc. – Oct 12, 2011 – Week 11 Page 3
When consumer is told they DO NOT qualify… If after evaluation of the information, the creditor decides that it will not approve the request and communicates this to the consumer, a creditor has treated a prequalification request as an Application, and is subject to Adverse Action. Regulation C does not require an institution to report prequalification requests on the HMDA-LAR, even though these requests may constitute applications under Regulation B for purposes of adverse action notices. Whether a creditor must provide a notice of action taken for a prequalification request depends on the creditor's response to the request. For instance, a creditor may treat a request as an inquiry if the creditor provides general information such as loan terms and the maximum amount a consumer could borrow under various loan programs, explaining the process the consumer must follow to submit a mortgage application and the information the creditor will analyze in reaching a credit decision. On the other hand, a creditor has treated a request as an application, and is subject to the adverse-action notification requirements if, after evaluating the information, the creditor decides that it will not approve the request and communicates this to the consumer. For example, in reviewing a request for prequalification, a creditor tells the consumer that it would not approve an application for a mortgage because of a bankruptcy in a consumer's record, the creditor has denied an application for credit.
Prequalifications must be contrasted with “What is an APPLICATION?” Understanding the distinction between an “inquiry” and an “application” is important for compliance with Regulation B because several requirements apply only to applications (not inquiries). Regulation B defines a loan application as: … an oral or written request for an extension of credit that is made in accordance with the procedures established by a creditor for the type of credit requested. The Federal Reserve’s staff interpretations of Regulation B further clarify that the phrase “procedures established”: … refers to the actual practices followed by a creditor for making credit decisions as well as its stated application procedures. For example, if a creditor’s stated policy is to require all applications to be in writing on the creditor’s application form, but the creditor also makes credit decisions based on oral requests, the creditor’s established procedures are to accept both oral and written applications.
FIC Regulatory Education Alliance / Copyright ©FIC Conferences, Inc. – Oct 12, 2011 – Week 11 Page 4
In other words, in some circumstances, informal inquiries, whether verbal or in writing, must be treated as an application pursuant to Regulation B. When a lender verbally disqualifies a potential borrower, even on a legitimate underwriting basis, the lender, according to Regulation B, is treating an inquiry as an application. Therefore, if enough information has been collected to deny a loan, and a denial has been communicated to the applicant, this interaction between a lender and prospective borrower is an “application” for the purposes of Regulation B. This is true, regardless of the amount of information collected by the lender, lender application procedures, fees paid to the lender, whether the prospective applicant has identified a specific property or loan amount, or whether the communication is written or verbal. These provisions affect mortgage prequalifications because, in situations where a prequalification meets the regulation B definition of an “application,” a creditor will need to provide a written adverse action notice. This is true regardless of where the applicant is in the prequalification process or how much (or little) information has been collected by the lender. In contrast to declined applications, as long as prospective applicants are being encouraged to proceed, lenders have reasonable discretion in defining what constitutes an application. The Regulation B staff interpretations indicate that “a creditor has the latitude under the regulation to establish its own application process and to decide the type and amount of information it will require from credit applicants.”
When is an Adverse Action Notice Required? ECOA requires the creation of a paper trail for all inquiries, including prequalifications, that meet the Regulation B definition of an “application.” Specifically, for all applications, whether written or verbal, Regulation B provides that: … a creditor shall notify an applicant of action taken within: (i) 30 days after receiving a completed application concerning the creditor’s approval of, counteroffer to, or adverse action on the application; (ii) 30 days after taking adverse action on an incomplete application, unless a notice of incompleteness is provided; (iii) 30 days after taking adverse action on an existing account; or (iv) 90 days after notifying the applicant of a counteroffer if the applicant does not expressly accept the credit offered.
Notice of Adverse Action must be in writing & must include the following: a. Name and address of the creditor; b. A statement of the action taken;
FIC Regulatory Education Alliance / Copyright ©FIC Conferences, Inc. – Oct 12, 2011 – Week 11 Page 5
c. A statement of the specific reasons for the actions or a disclosure of the applicant's right to receive the reasons within 30 calendar days if the statement is requested within 60 days of the financial institution's notification; - These reasons should be the principal reasons for taking adverse actions; i.e., statements that the adverse action was based on the financial institution's internal standards or policies are insufficient. - Disclosure of more than 4 reasons is not likely to be helpful to the applicant and therefore should be discouraged. - Statements that the adverse action was based on the applicant's failing to achieve a qualifying score on the financial institution's credit scoring system are insufficient.
d. Name and address of the federal agency administering compliance with respect to the creditor. e. Name, address and phone number of a consumer reporting agency from which information was received which contributed to the financial institution's decision to take adverse action. If information from more than one agency was used in this manner, each agency's information should be similarly disclosed. (If the reporting agency is national, a toll free number should be provided.) f. A statement that the consumer reporting agency was not responsible for the credit decision. g. A notice of the consumer’s right to a free copy of the credit report if requested within 60 days of receiving adverse action notice and a statement of the consumer’s right to dispute inaccurate information. h. Name, address and phone number of an outside source other than a consumer reporting agency (another financial institution or creditor) if information from such a source contributed to the financial institution's decision to take adverse action.
Record Retention Requirements A creditor must retain the required documents for a period of 25 months. In some cases, specific regulators may require retention since the last exam. In any case in which there are court proceedings, all records must be maintained until this is complete. The following should be retained: 1. the Application (and any attachments thereto) 2. the Notification of Action Taken 3. the Statement of Specific Reasons for Adverse Action 4. any Written Statement Submitted by the Applicant Alleging a Violation of this Act of this Regulation
FIC Regulatory Education Alliance / Copyright ©FIC Conferences, Inc. – Oct 12, 2011 – Week 11 Page 6
It is essential to remember, however, that the exemption from HMDA reporting requirements does not extend to Regulation B requirements regarding adverse actions or written applications. The Regulation C staff commentary notes that: … Regulation C does not require an institution to report prequalification requests on the HMDA-LAR, even though these requests may constitute applications under Regulation B. Lenders offer a wide variety of programs and services to assist customers in selecting and qualifying for various mortgage loan options. ECOA, HMDA and FHA and their implementing regulations should all be considered in designing and managing prequalification programs and services. In particular, lenders should be aware that prequalifications are subject to ECOA and FHA prohibitions from making oral or written statements that would discourage an applicant from pursuing an application based on any of the prohibited basis. As a precautionary measure and management tool, lenders may want to consider monitoring adverse action notices and application files to prevent, detect, monitor, and correct illegal discrimination. The time between the initial contact with the prospective borrower and the submission of a formal written application (the stage where prequalifications occur) is a stage where discrimination, intentional or not, is difficult to monitor, detect and prevent. Many lenders have developed second review programs in which applications that are likely to be denied are reviewed to ensure that all possible avenues for approval have been explored prior to formal denial. Prequalification “rejections” should be candidates for any internal program that takes a second look at rejected applications. Every lender should make sure that those verbal and prequalification denials are given the same consideration as more formal applications. Kimberly Lundquist FIC Conferences, Inc. 1150 N Loop 1604 W Suite 108-603 San Antonio, TX 78248
Tel 210.493.1761 Fax 210.493.9659 [email protected] www.ficconferences.com
FIC Regulatory Education Alliance / Copyright ©FIC Conferences, Inc. – Oct 12, 2011 – Week 11 Page 7
Supplement I Part 202 – Regulation B - Official Staff Interpretations Following is an official staff interpretation of Regulation B (12 CFR part 202) issued under authority delegated by the Federal Reserve Board to officials in the Division of Consumer and Community Affairs. References are to sections of the regulation or the Equal Credit Opportunity Act (15 U.S.C. 1601 et seq.). 202.2(f) Application 202.9(a) Notification of Action Taken http://www.fdic.gov/regulations/laws/rules/6500-3000.html#fdic6500supplementitopart202
HMDA – Official Staff Commentary on Regulation C SECTION 203.2—Definitions 2(b) Application http://www.ffiec.gov/hmda/pdf/regulationc2004.pdf
FDIC – Home Mortgage Disclosure Act http://www.fdic.gov/regulations/compliance/manual/pdf/V-9.1.pdf
NCUA – Home Mortgage Disclosure Act http://www.ncua.gov/GenInfo/GuidesManuals/HMDA_reporting/HMDAreporting.aspx
FIC Regulatory Education Alliance / Copyright ©FIC Conferences, Inc. – Oct 12, 2011 – Week 11 Page 8
