Publications Archive

Q: In determining whether the bank reports a HELOC for HMDA purposes, does the bank need to consider denied, withdrawn and approved but not accepted HELOCs into the threshold of 200? A: The count is based on the number of open-end lines of credit ...Read More

As planned, the Legislature did not meet in session this week.  After two busy weeks, this week’s hiatus provided an opportunity to reassess COVID protocols and sanitize the State House.  Over the next four weeks, the Legislature will meet for 10 legislative days, followed ...Read More

MONTGOMERY, Ala., February 12, 2021 — The Alabama Legislature met for a second consecutive three-day week, meaning even though the 2021 session began just last week, it is now one-fifth complete. Week 2 saw the quick passage of three major pro-business priorities, the introduction ...Read More

Q: We are getting requests from our lending team to give a residential loan to a borrower who is an LLC.  Are there issues with this?  A: Luckily if the borrower is an LLC or other legal entity, then the loan will not be ...Read More

Q: Our residential loan department is originating loans which are investment properties/non-owner occupied.  Would the bank be required to report the rate spread for HMDA purposes? A: If the bank has determined that the loan is not subject to Reg. Z because it is ...Read More

MONTGOMERY, Ala., Feb. 1, 2021 — The Alabama Legislature begins its 2021 Regular Session on Feb. 2. Thanks to the Alabama Constitution, everyone has known when this session would begin. But because of the coronavirus pandemic, no one really knows what will happen next. State ...Read More

Q: If the bank is escrowing for flood insurance is there a regulatory requirement to also escrow for real estate taxes or can the bank waive it? A: The federal regulations only require you to escrow for taxes and hazard insurance if the loan ...Read More