If an appraisal comes in low and causes the loan to have mortgage insurance, the borrowers challenge the appraisal and the results come back the same. The three day time frame for re-disclosing on a new LE to show the MI has passed and now the borrower wants to pay for MI upfront.
Is this a valid reason for a change of circumstance or is it now a cost to cure since the re-disclosures were not sent within three days of the appraisal received?
We have a consumer 30 year mortgage loan that was assigned to us from another financial institution that currently has PMI paid to a 3rd party. We offer our own PMI. Is it a requirement that we continue to pay the 3rd party under the original loan or can we switch to ours upon receiving the loan package?
Can anyone tell me if it is required to show PMI on the TIL?
We require that our members have an escrow account to pay their real estate taxes, homeowners insurance and PMI bills. When a member pays off his first mortgage, are we allowed to deduct the escrow balance from the payoff amount or do we have to refund the balance of the escrow account to the member? We have attended compliance seminars that advise us to refund the balance to the member however, our system is set up to deduct the escrow balance from the payoff amount.
Does HOEPA Chapter 49 Section 4903 pertain to PMI upfront disclosure or should I be looking in the Homeowners Protection Act? Where is that regulation?
Is the PMI tax included in the payment stream on the final TIL?
Does the annual PMI Notice need to be mailed or provided by January 31st each year?
The agencies have published new examination procedures for FCRA and the FACT Act.
Pre-paid finance charges. I argue that only Mortgage Broker and banking fees are PFC charges and that 3rd party fees (i.e. escrow, title, appraisal, etc) are not PFC's. What fees should be disclosed as PFC's?
Is there a compliance issue if you make an exception to your fixedrate home equity policy in order to extend the loan to value ratio from 80% 95% for one customer?