Does the Right of Rescission apply to a lease purchase? Reg Z specifically eliminates all "purchases", and ownership is not transferred until the actual purchace has been made.
Do the HPML rules apply to renewals of primary occupancy loans that were made prior to the new rules?
On an existing consumer R/E loan, where the loan has matured, if we use a consumer debt modification instead of a renewal note, do we need to do early disclosures?
If a customer is using his unencumbered personal residence to purchase a vacation home, is GMI required?
Do construct to perm loan mods need to meet MDIA guidelines, comparing the Construction TIL to the Permanent Loan TIL?
We made a construction loan last year. Physical construction is completed and we wanted to renew the loan as a construction (or bridge) loan until the borrower could move to the secondary market for his permanent financing. Are we subject to the new early disclosures and seven day waiting period to renew the loan for ninety days? Are we also subject to the new Reg Z caps/constraints for this short term extension?
If an individual uses his personal residence as collateral for the purchase of a rental home, is this a business purpose under HMDA? If not, how do I show his approved application (loan not closed/funded) on the LAR?
We seem to be faltering back and forth with regard to renewal versus refinance. We have three year mortgages that are renewed at the end of the three years. With a renewal, an application is not required. We do take a new note with a new number, but we do refer to the previous note number that the loan is renewing. Should we be using the same note number and are the RESPA disclosures required? Also the changes on Regulation Z effective as of 7/30/09 do not reflect renewals, but refinances they do. What are your thoughts on renewal versus refinances?
Is there ever a circumstance in which government monitoring information would be collected for a home equity line of credit?
I have a new commercial loan with the purpose of refinancing an existing loan (secured by mixed use property) and to purchase a Condo investment property. The mixed use property has a 1-4 dwelling on it, but also has commercial buildings on it as well (a catering business). The commercial buildings have more square footage than the 1-4 dwelling. Is this commercial loan HMDA reportable? The new loan is not a LOC, but is a one time disbursement with PandI monthly payments.