A customer provided hazard insurance and there is a deficiency in the dwelling coverage. Is there a model letter available for deficient coverage amount to send to the customer?
When it comes to the rule of force placed insurance notification. Is doing a protective advance on a loan considered forced-placed?
In the new TIL Rules Is it required that an institution force place hazard insurance? Can we choose not to? We are a small servicer by definition.
Our bank recently decided to purchase Mortgage Blanket Insurance to use in event borrowers lapse on their hazard insurance on a mortgage the bank has secured as collateral so that the bank will have coverage for the ownership interest of the real estate. This insurance is obtained through an insurance agency which is a subsidiary of the bank. The borrowers of course will not be incurred a charge for this. Are we required to provide an Affiliated Business Arrangement? Is there any other requirement that we must do for this?
If our institution waits the 45 days required after both notices regarding a borrower's lapse in hazard insurance are sent, and then force place, can we back date the policy so that it is in effect the day of cancellation and still be in compliance with the Dodd-Frank Act? The second part is this: if this is not in compliance, how can we structure force placement of the insurance, and the notices required, so as to be in compliance, and still make sure the home is covered? Basically, would our institution have to â€œfoot the billâ€ for that 45 days?
What method(s) are being used to determine insurable value when calculating the appropriate amount of forced placed insurance?
Can an institution keep paying ACH's (ins.pymts, phone bill, etc...) on a single party account if the owner is deceased?
Regarding the new changes that went into effect 1-1-2010, the one that I am having an issue with is the charges that are supposed to be listed on the new GFE. I told my boss that all charges that are related to a residential one to four family real estate loan, have to be listed on the GFE whether or not we are going to actually charge them. He states there is no reason why if we know up front that we are going to charge one of the fees, why we should have to list it on the GFE. I told him that the new changes state that we have to do this, so I have to have prove where the reg actually states this. He said he isn't going to go by someone's opinion of the reg (such as from a seminar/webinar). He wants it straight from the reg, so am I correct in stating this? If so, please provide me the reg that states this and the explanation.
We're traditionally a home equity lender who has never tracked hazard insurance. Under the high priced mortgage rules, we are now required to escrow for taxes and insurance if it's an HPM and a first lien. Are we required to force place hazard insurance to comply with Reg. Z if we have an uncooperative borrower who has cancelled his insurance even though we are escrowing?
Our bank currently does not escrow taxes and insurance. In a third party review it was stated that we should still give an estimate on the GFEs. Does the servicing disclosure have to be signed (RESPA)?