How do we know when a cushion is allowed?
We often have lobby posters advertising products, services, benefits like trips on a discounted price and others things on display so staff can answer questions on these and to promote these items. Do they require the general FDIC advertising statement>
If we price HELOCs based on the applicant's credit score and loan to value ratio, so some borrowers get a lower rate than other borrowers, can we disclose the lower rate in our advertisement, or do we need to disclose both rates? Do we also need to specify the criteria for receiving the lower rate?
There are competing thoughts on the appropriate way to treat an application when the Loan Estimate is not provided by the 3rd business day following the applicant's submission of the six pieces of information.
Theory 1 - Cancel the existing application and restart the application process. This may be due to some issues with selling the loan on the secondary market.
Theory 2 - Show it cas a "self-identified" issue on the file and continue with the file as is. As long as it is not a pattern in practice and is just a one-off from the established controls, there should be no ramifications.
Please help in identified whether #1 or #2 (or may be a 3rd option we aren't thinking of) would be the most appropriate.
Is there a time limit on the construction phase of a one-time close construction-perm loan? In the old days, Reg Z limited the construction phase to 12 months but I'm unsure what apples now.
I have a closed-end consumer 1-4 family refinance with new money being loaned. This loan has a right of rescission. Am I to collect interest on the refi loan to the date of the loan or the day it comes out of rescission?
Is following the standard Regs, B, Z, DD and fair housing going to ensure advertising compliance?
How do we resolve a conventional 30 year residential loan, originally floating at application, that was closed without being officially "locked," at the rate originally stated on the LE, which did state that the rate was floating? Will the resolution differ if the now current market rate has dropped lower than the original stated rate versus an increase in the rate?
We have a loan that was a HELOC. Our customer is now renting the property so he applied for a commercial loan. Can we modify the open end deed to a closed end deed?
My bank is a small creditor who makes HPMLs. We’ve been claiming the escrow exemption, but now I’m not so sure we should. Sometimes we set up accommodation escrows for extenuating circumstances – does that cause problems?