Loan Modifications: What Are the Compliance Issues?
Making changes to existing loans is a challenging endeavor, especially in today’s environment. Lenders are facing unprecedented requests to make changes to loans of all types – mortgages, credit cards, consumer loans, small business loans, and so forth. What are the critical compliance implications when dealing with these requests? What types of disclosures must be provided, if any? Must new appraisals be obtained (and how do we do that if appraisers can’t do on-site work?) Must rescission rights be provided?
This webinar will deal with the ins and outs of making changes to loans of all types. We’ll discuss the compliance and legal requirements, operational challenges, and impacts to borrowers, guarantors, and other parties to the loan. We’ll also deal with the threshold question: should the lender grant the borrower’s request in the first place (and if so, what accommodations or changes should be made)?
What You’ll Learn
- Disclosure requirements, if any it depends on how the changes are made
- Appraisal requirements
- Flood insurance what to do here?
- Tax implications
- Defaults what special requirements are in place here?
- Troubled Debt Restructuring (TDR) issues
- Fair lending implications disparate treatment and impact
- Handling borrower requests and complaints
- Dealing with government-backed loans (FHA, VA, Fannie/Freddie, etc.) new pronouncements
- HMDA and CRA reporting
- Consumer, mortgage, and commercial loan issues
- BSA issues, including beneficial owner requirements
- E-SIGN and Remote Online Notarization (RON) possibilities
WEBINAR DETAILS
Changing an existing loan can bring on a number of issues, including whether new disclosures must be provided, a new flood determination must be obtained, and many more. We’ll explore the many requirements that must be met.
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