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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?

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?

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.

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Most Popular Compliance Content

Church/Credit Union: Non-government Organizations?

08/01/2021

We are going back and forth as to whether or not a credit union or a church are actually considered non-government organizations? Although we know that they are non-profit, I have read conflicting information and am trying to settle this internally.

Handling Reg E claims on older transactions.

07/25/2021

If an EFT claim is made long after the statement is sent showing the transaction, the rules of investigation don't apply. So why do we investigate any of these claims?

Compliance Info on Paper Checks

07/25/2021

I was wondering if you could point me in the right direction as to where to find more information on compliance for paper checks? Whenever I place a stop payment on a paper check, there's a disclosure that says "this request will expire in 6 months in order to comply with regulatory requirements." For the customers who ask for a more in-depth answer, what can I tell them?

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