I made a loan to three individuals on a mobile home (no land involved); two of those individuals will make the mobile home their primary residence. Is the loan subject to HPML?
In a question that was posed to Patricia Cashman on 7-19-10 concerning HPML and modifications, she stated that escrow will not apply to a true modification. Could she please show me where that can be found in the regulation. I have looked and can't find this. I have this situation and I need more clarification.
I know loans for the initial construction of a dwelling are exempt from HPML, but does it matter if we know we will be doing the permanent financing when the construction is complete?
Do the HPML rules apply to renewals of primary occupancy loans that were made prior to the new rules?
Do the new HPML rules extend to a primary residence offered as collateral by a third party?
I need clarification on balloon payments. Are we not allowed to have balloon payments on any loan or does it just apply to HOEPA, high rate high fee loans?
Do non-HMDA reporting banks need to report high cost loans?
Are Higher Priced Mortgage Loans for loan applications dated on or after Oct 1, 2009? How would you suggest banks handle ARMs that have been on the books prior to 10/01/09? Would these fall into the HPML when these get re-priced?
The handout for the Reg Z, New Early Disclosures webex indicates on page one that the HPML rules that go into effect on 10/01 do not apply to manufactured housing until 10/01/2010. I need a citation for this, as I can't find anything to back it up. I see where the escrow rules for these loans aren't effective until 10/01/2010, but I'm referring to the income, asset, obligation rules, etc.
Is HPML triggered when I modify a matured note, meaning there is no new note, no new money and the terms are not changed other than the interest rate?