Our bank would like to offer a 20/15, 25/15 and 30/15 loan where the interest rate is fixed for 15 years then changes one time for the remaining term. Everyone we've talked to says these are ARM loans. However, in our loan platform all ARM programs must have a subsequent rate and payment change date. Is anyone else offering these products? If so, how are they disclosing?
We are trying to create an ARM loan and it will be on a 15-year note with rate changes every 5 years, basically changing twice. Is there a maximum ceiling rate/floor rate we can charge?
If subpoenaed for a Grand Jury, can a bank disclose the existence of or any information related to a SAR (asked by the AUSA in front of the grand jury)?
We are changing the term from fixed rate to variable rate on a work-out consumer term loan secured by their residence which is a manufactured home on leased land. We prepared change in terms documents consisting of Promissory Note and Disclosure document. The document states "disclosures about the variable rate feature have been provided to me earlier." (actually they were not). Are any other disclosures required?
We have a mortgage on property that was originally investment property. The property is now being used as the borrower's primary residence. We want to only lower the floor on this loan, which is an ARM. Would any disclosures be required?
If a home loan is exempt from RESPA because it is situtated on a sixty acre tract of land, is the ARM early disclosure and booklet still required at time of application?
We have a customer who took a 3/3 ARM four years ago. It adjusted at the three year mark as normal, but then adjusted one year later (last month). When the customer contacted us, we realized that it had been mis-entered in our system as a 3/1. The customer has benefited from a lower rate at this point (first new payment is currently due), but we are not sure of the implications from correcting this. My thoughts are to do one of three things: 1) Allow this payment to be made at the lower rate, but change the product back to the 3/3 at the current (higher) rate for the remainder of the term. 2) Offer to keep the lower rate and do a modification to a 3/1 if the customer accepts. 3) Change the product back to the 3/3, but keep the lower rate for the remainder of the period (2 years) Any thoughts from a compliance or legal standpoint?
I found while auditing a file, that a mortgage loan was disclosed as a 30 year product but the note and loan closed as a 5/1 ARM. I'm trying to determine my next course of action regarding this matter. Do I need to redisclose and book the loan as a 30 year fixed even though the note is a 5/1 ARM?
Are there any specific guidelines regarding an ARM loan for a second residence?
We want to make mortgage loan applications available on our internet banking website. What are some of the issues we need to prepare for?