We have a customer with a mortgage loan who did not want to have the bank escrow for taxes and insurance when the loan was originated. The customer now wants the bank to escrow these items. Can the bank provide the customer with an initial escrow disclosure, and a HUD-1 indicating the cushioned amount without having to provide any other additional disclosures, and still be in compliance with all of the other regulatory disclosures (i.e. Reg Z)?
RESPA - in the answer by Dan Persfull to a question about RESPA forms, he mentions a short form Servicing Disclosure statement. I am aware that several years ago this was proposed, but I did not see a final rule come through the Federal Register. Could Mr. Persfull please provide the cite for the use of the short form disclosure?
Is it necessary to disclose ad valorem/real property taxes on non-purchase loans? We never escrow this because the customer is required to keep taxes and insurance current. If it is a good practice to disclose this (POC) as we do hazard insurance, then how exactly is it disclosed? Is the tax amount that was paid for the previous year what is disclosed?
We are currently in the process of starting a loan servicing/credit administration division in our $237 million dollar community bank. What are the major issues that we need to ensure are covered? Our division is going to handle everything related to a loan in the post-closing stage to payoff.
Several years ago, HUD published a proposal to revise the Good Faith Estimate required by RESPA. The proposed changes were significant.
Pre-paid finance charges. I argue that only Mortgage Broker and banking fees are PFC charges and that 3rd party fees (i.e. escrow, title, appraisal, etc) are not PFC's. What fees should be disclosed as PFC's?
I am a Mortgage Broker. I was referred to this web site from the Department of Real Estate. I needed to know what forms are included in the "RESPA" Disclosures to keep us in compliance.
Ever since its implementation, the efforts to develop and implement a Customer Identification Program have been fraught with questions.
Question: We are making a loan secured by a condominium unit. The condo association has a flood insurance policy that covers all the units.
Question: We are making a home improvement loan to a customer. Can we prepare disclosures the way we would for construction loans?