Vendor Guru Q&A - Compliance

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Latest Compliance - HPML Topics

Verifying mortgages for HPML status

04/09/2017

I am auditing a bank and verifying consumer 1-4 family loans are not HPMLs. I am using the Closing Disclosure date and APR to perform my testing. Am I using the correct date and APR?

Lot Loans and HPML

09/18/2016

Are lot loans exempt from HPML?

HPML Rules for First Lien Home Equity Installment Loans

07/05/2015

What are the HPML rules for a home equity installment loan when the lien for the home equity installment loan is a first lien?

Higher-Priced Mortgage Loans on Mobile Homes

05/31/2015

Do we need to test for a mortgage loan being a higher-priced mortgage if it is for a mobile home purchase? It will be the consumer's principal dwelling and no land is being taken as collateral.

Change Purpose (Consumer to Business) HPML?

03/11/2013

Scenario: Consumer purpose balloon loan that was originally the borrower's primary residence and fell into the HPML category. The borrower no longer resides in the property and it is now a rental. Since the purpose has changed from consumer to business, do HPML rules still apply? Can we cancel the escrow account? FYI-we are still within 12 months of origination.

Reg Z Escrow for Separate Tracts of Land

02/11/2013

I understand that Reg Z requires us to set up an escrow account for loans that qualify for HPML. If the security is made up of separate tracts of land and only one of the tracts includes the first lien on a principal dwelling are we required to escrow for taxes and insurance on the other tracts of land?

Available Cures if HPML is Closed w/o Escrow?

07/23/2012

Are there any available cures if an HPML is closed without escrow?

HPML Calculation Performed Incorrectly-Remedy?

06/04/2012

What if an HPML calculation was done incorrectly, later discovered to be an HMPL, and the first-mortgage loan closed without escrow? Is there a remedy?

Additional Disclosures for Closing HPML Loan?

04/16/2012

Are there additional disclosures required if a lender does choose to close an HPML loan when the loan fails HPML but passes Section 32?

Variable Rate Real Estate Loans-Debt/Income Ratio

10/31/2011

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.

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Seven Year Income Reduction Lending Policy

Question: We have an applicant whose current income consists of a SS payment plus a monthly payment from an inheritance.

Even More Regulation Z: How to Underwrite

If you thought you had Regulation Z all figured out and neatly organized, you don't. The Federal Reserve just proposed changes to Regulation Z that will turn your comfort level upside down.

Info on Deceased Customer's Safe Deposit Box

10/20/2019

We received a call from a customer's child asking for information about a safe deposit box in name of our customer who is now deceased. This person was listed on signature card but never signed it. Should we give him any information regarding the closing of the box?

Latest Compliance - HPML Topics

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