Do we need to have a non-borrower owner of title sign an initial TIL and GFE for a RESPA transaction? Reg Z talks about material disclosures, but I can’t find what is considered a material disclosure. Which other documents besides the deed of trust and riders need to be signed by a non-borrower owner of a property?
In the HUD settlement for a purchase of a 1-4 family dwelling for rental purposes, the title company included a broker fee in addition to the commissions earned by the real estate company as part of the settlement to be paid at closing by the buyer/borrower. Should we accept this as part of our settlement without proof that the fee was earned by the real estate agent? Assuming it is a legitimate fee, should this be disclosed as a finance charge for APR calculation?
What is the tolerance for an understated APR violation?
We use life of loan flood determinations. Are we in compliance for listing the full amount of the fee as a prepaid finance charge? This fee affects the APR which ultimately affects the rate spread in HMDA reportable loans.
Our marketing person would like to offer $100 off loan closing costs on mortgages until the end of June with a cutout coupon in the newspaper. Would we have to show this as a POC on the HUD and does it affect the APR?
We are looking for ways to increase fee income and raising our VSI premium was mentioned. Can we charge a few dollars over the actual premium and still be in compliance? Reg Z was the first thing that came to mind. Please let me know what you think.
Regarding open lines of credit for an ITI Bank, all the disclosures are given for finance charges, etc. on the loan documents, but according to a new interpretation of Reg Z these fees need to be itemized and disclosed again on the initial billing statement. Where in Reg Z is this stated?
We have a personal closed-end line of credit with a term of nine months. We are anticipating multiple advances during the term of the credit up to the maximum amount. According to 226.17(c)(6)(i) a series of advances under an agreement to extend credit up to a certain amount may be considered as one transaction. When disclosing the Fed Box items, APR, Finance Charge and total of payments must the "e" (for estimate) be placed in each of these boxes?
Does Reg Z apply on a consumer loan for $1,000 with less than 50% for business purposes?
Is it true that if you have an underdisclosed TIL by more than $100 and it's only due to prepaid interest, it is not considered a violation?