With regard to HMDA, is there any difference between a Home Equity Term Loan and a HELOC?
Are the Good Faith Estimate and HUD-1 disclosures required for home equity loans? I have seen specific references to Home Equity Lines of Credit, but not HE loans.
Does ROR apply to a loan for the purpose of paying off credit card debt? We have an existing future advance deed of trust already in place at the borrower's primary residence that we will be using to secure the loan.
Is there ever a circumstance in which government monitoring information would be collected for a home equity line of credit?
After over twenty-five years of issuing preliminary TILs in certain home equity loan transactions, my new bank is telling me it is not required and only necessary at closing. What's the truth in truth in lending?
My studies indicate lines of credit are optionally reported (we do not report). Most of the writings seem to equate lines of credit with home equity lines of credit with no distinction between closed-end and open-end. Are there different reporting rules for open-end and closed-end lines of credit?
Is a bank or credit union still required to provide a Home Equity Early Disclosure showing a 10 or 15 year history of the rate? If so, what is the Reg that governs this requirement?
Our bank has two offices in rural areas and assets of approximately 42 million. We hired a loan officer to work in an MSA. He may be creating 1-4 family residential real estate loans or home equity loans. The office is not an official branch and is still not an official LPO. Will the bank be subject to HMDA reporting?
I have read the following statement under Reg B staff interpretations of 202.13 (#5) "an application for open-end home equity line of credit is not subject to this section unless it is readily apparent to the creditor when the application is taken that the primary purpose of the line is for the purchase or refinancing of a principal dwelling". To me that means that if an applicant applies for a HELOC with the intention of purchasing or refinancing their home that we (the lender) should gather government monitoring information. Am I understanding correctly? If I am, what is the creditor supposed to be doing with the GMI? For HMDA we report the GMI on the HMDA LAR, but there is not a Reg B LAR to my knowledge.
When a customer applies for any type of credit with our institution (such as a credit card, consumer loan, commercial loan, home equity and/or mortgage loan) are we required to obtain written authorization, as in a signed application, before pulling the credit report?