Can a home equity loan in Texas have a call feature (e.g.-15 amortization at 5% fixed with a three year call)?
What are the HPML rules for a home equity installment loan when the lien for the home equity installment loan is a first lien?
What is the 3-day rule when a HELOC is being converted into a HE loan? I'm in Operations and we have problems when a loan officer starts a Presentation without including us and then sends us the information about a month later. Do we concern ourselves about not getting the information early enough to send the preliminary disclosures within the 3 days? This is an ongoing problem that we would like to settle once and for all.
Are any TILA disclosures required when an open end HELOC has the option to fix portions of the line during the draw period? The fixed loan options are tied to the line and work like a credit card with fixed rate options.Where in Reg Z is this addressed?
We currently have Home Equity Lines of Credit (open ended) that have floor rates of 6.00% and 7.00% and we would like to reduce these to our new floor rate of 4.25%. I know under Reg Z Section 226.5b (f) it states we can make a change that will unequivocally benefit the consumer throughout the remainder of the plan. With that being said what type of documentation and disclosures must be given in order to stay in compliance with the regulators and terms of the loan? We want to ensure that if we do a modification agreement on the HELOC we do not need to redisclose on the loan.
I am renewing a loan that was originally a HELOC. The loan matured and I collected an updated "consumer HELOC" application and obtained a new credit report. The loan was approved for renewal but for a lower amount and shorter term. I was told that I should not have collected a new loan application (purpose on application was stated a renewal of HELOC) because this is not a new loan request. No new disclosures were required and only a simple form modification agreement was needed to renew the loan. Can you please advise as to what documentation would be need for this type of transaction?
Are advances on lines of credit (such as a Home Equity Line) to officers who later, during the life of the line, become Executive Officers required to be approved under Regulation O? Is each advance an "extension of credit" since a line of credit does not constitute a "binding Commitment?"
We recently had an FDIC compliance exam and were criticized for gathering information on some home equity refinanced loans. We had been told in the past that if it was a refi, we should get the info...we are not a HMDA reporting bank. This examiner said that according to Regulation B it depended on what the principal percentage of what the refi was used for...either purchase money or HE. We checked with several non-HMDA banks and they are doing it like us. The examiner said we could question it, but this was his determination. Any help?
We have a customer with two home equity loans secured by a third and 4th lien. We want to consolidate these into one loan with a small principal payment instead of the current interest only payments. There is no new money. What Disclosures (TIL, RESPA) are required?
I have a request for a home equity loan on a second home. What determines that the property is a second home and do I send the same disclosures as a primary residence?