We're traditionally a home equity lender who has never tracked hazard insurance. Under the high priced mortgage rules, we are now required to escrow for taxes and insurance if it's an HPM and a first lien. Are we required to force place hazard insurance to comply with Reg. Z if we have an uncooperative borrower who has cancelled his insurance even though we are escrowing?
We are confused about when MDIA applies on two loan types. Does MDIA apply when you are taking a mobile home without the land as collateral? Does MDIA apply when you are taking a consumer's principal dwelling as collateral for the purpose of business capital?
I am trying to find if there are any exceptions to the "Right to Receive Appraisal Notice". Is it all loans secured by lien on a dwelling, whether commercial, non-owner occupied, etc?
Is there a HOEPA worksheet available that is for loans after 10/1/09? My understanding is that if the APR on a first lien principal dwelling loan exceeds the average prime rate offer by 1.50%, the loan is considered a HOEPA loan.
We have an independent appraisal from another institution. Does the notice of right to receive a copy of an appraisal still apply?
If we have a balloon note coming due and we are going to extend the loan out, is it HMDA reportable? We are changing the loan number with no new money and we are not satisfying the mortgage. The original loan is within the same financial institution as the renewal. We reported it at origination of the original loan so if we report it again will it be double reporting?
If a consumer has a primary residence then purchases a vacation home and asks for a loan with the vacation home as collateral, does RESPA apply?
Reg B 202.14(a) says that the appraisal requirements apply to any loan secured by a lien on a dwelling. Does this apply to the construction phase? In other words, does this need to be provided to the customers even though the dwelling has not been constructed yet?
Where can I find a sample form of the HOEPA disclosure? I have never needed one before, but now have a closed-end junior lien with credit life and disability.
I have a RESPA question. Do we need to give all the disclosures such as early TIL, GFE, Info Booklet and the servicing disclosure for a home equity closed-end loan?