The 'dwelling' definition states the number of acres is not considered for HMDA; however, the farm loan exemption states an institution may use a reasonable standard to determine the primary use of the property, such as Reg X's definition. This seems conflicting since Reg X states the use of the property does not matter.
If the initial GFE did not list the name, address & phone number of originator can they do a revised one and be okay or will they have to use $0.00 on the HUD-1 comparison and pay the borrowers the difference between $0.00 and the actual cost?
If a customer asks for a pre-approval for a purchase of a specific property and amount does this trigger a GFE and is it considered an application?
We are conducting an internal audit on RESPA. We have noted several variances on the HUDs with different processors. The section titled Loan terms at the end of the HUD that has information concering the rates and dates and payment dates on variable rate loans is filled out different with each processor. Is that something we need to correct and if so what is the best way to do this. Some are not filled in at all.
If we create an open house listing sheet and cobrand it with a realtor, would this be a RESPA violation if we, the lender, paid all costs for production of the flyer? A listing sheet includes the property address and some financing scenarios for the specific property.
We are going to start offering Debt cancellation insurance on 2/1 replacing credit life, etc. We can set this monthly in and out fee up on our core system as Other Escrow but need some clarification if this is going to make the loan be required to run through an escrow analysis every year? These payments would never change, a payment would collect then wash out immediately to CSO.