Are creditors allowed to deduct escrow balance from the principal when the loan pays off? The outside auditors we use for Compliance review is saying it is acceptable but when I went to Bankers online I get a different response. Which is correct?
Reg Z - I have a borrower who is using his mother's primary residence as collateral for consumer purpose. The mother is not going to be on the note itself. She is just pledging the collateral. Would the Higher Price Mortgage requirements apply and is an Escrow required?
Do we need to escrow taxes and insurance during a mortgage construction phase of 1 year?
We do not escrow insurance at our bank. We have several customers and businesses who continually neglect to pay for their hazard or wind insurance on time. Is it permissible to require these customers to submit proof of 12 months paid insurance as a requirement of not force-placing insurance on their loans?
I am working on a new loan transaction. The borrower is purchasing a primary residence and the loan will be sold in the secondary market. The 20% down payment will be borrowed against his home that is currently his primary residence that he owns free and clear. After the purchase is finalized, he will be living in the new home as his primary residence and the home he owns now that will be securing the equity loan will be used as an investment property. Does RESPA apply to the equity loan? Do early disclosures have to be issued? Also, does rescission apply to the equity loan since it is in fact his primary residence at this time. Also, since the equity loan will be kept in-house on a balloon rate, will this be considered a HPML where escrow will have to be collected?
Does an initial escrow disclosure have to be mailed out with the early disclosures for residential property?
On a consumer loan secured by a certificate of deposit, is it required for the "Required Deposit" box to be checked in the Fed box disclosures?
I'm wondering if we can use the escrow analysis spreadsheet spreadsheet on this website for 2011 even though it says it was created in Jan 2010.
In a first lien home equity loan against a dairy and primary residence where the funds are to pay commercial taxes, not for a consumer purpose, would the escrow requirements under the HPML come into play?
Currently we perform annual escrow analyses based on the anniversary date of the mortgage, but years ago we only performed analysis during two particular months during the year. What Reg covers this and what is stated regarding analysis? If we wanted to move to a few times a year instead of monthly, we'd have to create either a short or long analysis for customers to accomplish that but I'm hesitant to consider that change.