Our bank will be reporting Home Equity Lines of Credits for HMDA. Although we are not certain what the guidelines are for the loan amount, we understand we have to report only the amount intended for home improvements. For example, do we use the amount they draw at closing? Please clarify how to determine what amount to use.
When does the new good faith estimate form go into effect?
In business credit, Regulation B states oral notification needs to be documented; what does this mean and entail?
Do we need to provide a TIL disclosure within three business days of receiving an application for a construction loan on applications received after July 30, 2009? Our construction loan term is twelve months or eighteen months. Are we allowed the temporary financing Reg Z exemption under the new MDIA ruling?
Are Higher Priced Mortgage Loans for loan applications dated on or after Oct 1, 2009? How would you suggest banks handle ARMs that have been on the books prior to 10/01/09? Would these fall into the HPML when these get re-priced?
We have some customers that present us what is called the United Nations passport as form of identification. On their applications they state their nationality. For a while, we have considered that ID as valid, but now we are having second thoughts. Would you accept that form of ID? I understand it is not issued by the government, but it has a picture, signature and expiration date and is accepted for crossing borders.
The changes to RESPA by HUD includes a revised definition of application. One of the elements which make up an application is described as "an estimate of the value of the property". How should this be documented on the application form to ensure compliance? The residential loan applications which are provided in our loan processing system (ARTA) do not have this item included on the form.
Am I correct in stating that the TIL must now be given early and there is not an additional one required unless APR becomes inaccurate?
The new RESPA changes have an effective date of 1/01/10 for the revised GFE and HUD. Is that for applications dated 1/01/10 or later, or for loans that close 1/01/10 or later?
Regulation B - for business loans (all sizes) or commercial real estate loans (CRE), are we required to have a credit decision (approved, denied, or counter-offer, etc.) within 30 days after receipt of a completed package, same as for consumer credits?