Articles

HMDA: The Significance of Conditional Approvals and Approved But Not Accepted Applications

December 20, 2019 - 5 min read

The Home Mortgage Disclosure Act (HMDA) requires institutions to indicate what “action” was taken on reportable applications. The institution must choose between a finite list of these actions to describe what exactly happened to the covered loan or application. What was the ultimate outcome? Was the transaction originated or purchased from another institution? Was the…

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Risk Management Guidance for Higher-Loan-to-Value Lending Activities in Communities Targeted for Revitalization

September 30, 2019 - 5 min read

On June 19, 2019, the Office of the Comptroller of the Currency (OCC) issued OCC Bulletin 2019-28 Risk Management Guidance for Higher-Loan-to-Value Lending Activities in Communities Targeted for Revitalization (the 2019 Bulletin) and rescinded its prior bulletin of the same title, OCC Bulletin 2017-28 (issued August 21, 2017) (the 2017 Bulletin). The purpose of the…

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