We have a mortgage on property that was originally investment property. The property is now being used as the borrower's primary residence. We want to only lower the floor on this loan, which is an ARM. Would any disclosures be required?
A client is refinancing a second home in another state, would this loan be disclosable?
Is there a timing issue for HMDA reporting? Assuming we meet all other requirements, we have loans where the purpose is to purchase a dwelling, but the applicant has had to pay cash because it was a foreclosure, and we have loans for home improvement, where the improvement has been done with cash and the applicant wants to be reimbursed through loan proceeds. Are these HMDA reportable, or do the proceeds have to be used for the actual purpose?
Is the refinance of a loan to be secured by shares of stock in a cooperative corporation subject to the right to rescission under Reg Z? The borrower does not own the property, he/she owns shares of stock in the cooperative which allow him/her the right to possess the unit. The cooperative corporation owns the property.
I am refinancing a loan for a customer which will be used to purchase a primary residence to a home improvement loan(but he will not move into the property until the home improvement is completed), does rescission apply?
If an old loan was for home improvements and the borrowers are refiniancing with new money which is not being used for home improvements, would this still be considered a home improvements loan for HMDA reporting?
We are refinancing a loan that is secured by two manufactured homes and one dwelling. What property type code should be used on the HMDA LAR?
Regarding HMDA loans: if a loan is considered to be a home improvement loan if the funds are used to finance improvements, but not so if the proceeds pay the borrower back for improvements already made, then how would we report a loan made for improvements that are made in the past if the borrower is not getting the money back, but rather paying off the credit card and/or LOC used to finance the improvements? The improvements have already been made, but the proceeds are not paying the borrower back directly and are in a way, still financing the improvements.
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.
Our compliance department has determined that GMI is not required for mobile home loans without land. Is this correct?