12/01/2003
Our bank intends to charge residential mortgage applicants a $500.00 nonrefundable application fee but no appraisal fee, credit report fee. Bank will pay the appraisal fee and credit report fee to the 3rd party vendors. Questions: 1. Do we need to disclose the payment of the third party fees as POC in the GFE and HUD1? 2. Does the nonrefundable application fee, which applies to all applicants, need to be a APR item?
10/06/2003
Reg B This is regarding the changes in the Uniform Residential Loan Application. Do you know if anyone is taking into account (while changes are being made) the changes that will be put in place by the USA Patriot Act? I am referring to the additional information required to be collected at application to identify the borrower.
09/02/2003
I am having a horrible time trying to get the concept of figuring the fee's on a loan, to verify that it's not, or is, a HOEPA loan. Is there a calculator that can do this for us? (other then the worksheet!) I have a very difficult time, trying to figure out which fees need to be where.....thank you for taking the time to read this!! And thank you in advance for the help!
08/04/2003
I'm not sure how much flood insurance I need for this loan with five buildings on one piece of property. The loan amount is $2 million. The appraisal was for $2.4 million. One building appraised for $233,280 the other four buildings appraised for $391,680 each and land is for $600,000. Is the maximum amount of flood insurance available $500,000 for all five buildings or is it $500,000 per building? Can building one have $233,280 in insurance and the other four buildings have $391,680 for total coverage of $1.8 million or is it the total amount of insurance only $500,000 divided among the five buildings?
07/01/2003
There is nothing quite like going through a mortgage settlement to get a fresh perspective on compliance, regulatory burden, and paperwork in general.
05/26/2003
04/14/2003
We are having an argument over whether a correspondent mortgage lender can charge a single processing fee which will cover credit, appraisal, flood, etc. as well as processing and not enumerate the third party provider charges specifically. Could you give me some specific guidance regarding this question? I am working on the basis that we can only charge exact fees and that by bundling we run up against the presumption that we are marking the fees up beyond their actual cost which will be a violation of RESPA.
03/24/2003
Are Appraisal Review fees and environmental report fees considered prepaid finance charges?
12/16/2002
I have two questions regarding Reg B's requirement in section 202.5a to provide appraisal copies. 1) Does this requirement pertain to commercial loans where you take a dwelling as additional collateral in an abundance of caution? For example, we will often make a commercial line of credit secured primarily by a UCC1 filing against business assets, but secondarily by a lien on the owner's residence. 2) What if you do not do an appraisal. On many of our small equity loans we will use the assessed value or consideration paid to value the property not doing an appraisal at all. Would we need to provide the notice in this case?
11/01/2002
Question: We closed a refinanced home loan several days ago and the customer just called to rescind the loan.