Our software company recently changed the TL Statement on HPML Real Estate Loans to disclose a maximum payment amount on Variable Rate Real Estate Loans (maximum during first five years). We understood that the Debt to Income Ratio on these Loans were to be based upon the maximum during the first 7 years after consummation. Please Help.
Is an OFAC check required for opening an estate account?
If a Court Appointed Administrator dies, should the Estate Account be closed before a new administrator is named? Can the newly appointed administrator with court documents come in and handle the account?
If I take a second REM in an abundance of caution for a loan workout situation, are early disclosures required? The loan was originally an auto loan.
A client's spouse passed away in November 2010. The Client was POA on a retirement account. The account title has not been changed since his death. Can she take a withdrawal?
We are refinancing an existing non-dwelling secured home improvement loan and advancing new money for personal expenses. Is this HMDA reportable, and if so, would it be a refinance or a home improvement?
We have the opportunity to refinance a commercial real estate loan from a competitor. The subject property was appraised by an approved appraiser within the last 12 months. The appraisal was ordered by the competitor. The competitor bank won't release the appraisal directly to us, but the borrower has a copy. Our compliance officer says that we must order a new appraisal because accepting the copy from the borrower would violate the latest interagency appraisal guidance. Any options available besides a new appraisal?
A bank charges a $20 credit report fee for consumer real estate loans, but the fee is actually less. Should the amount that is in excess of the actual cost be considered a finance charge for Reg Z purposes? I realize there is a huge RESPA issue in this practice as well.
Can an institution keep paying ACH's (ins.pymts, phone bill, etc...) on a single party account if the owner is deceased?
I recently attended a Harland Laser Pro Regional Conference. It was indicated that the SAFE ACT states that mortgage lenders must register for a NMLSR. Does this include loan officers that just take Home Equity Loan and HELOC applications?