Can we make non-QM HPMLs, and if so, what do we need to watch out for?
We have a customer that wants to opt out of email/mail and telephone contact with us. In fact we have no telephone number on file to contact him. He doesn't want emails or letters. My question is, are we required to comply with requests for opt out to include postal items and email?
Does the Right of Rescission apply to a refinance of an existing HELOC with a new HELOC for a larger amount? The lender is the same institution, and there is new money.
Our bank would like to offer a 20/15, 25/15 and 30/15 loan where the interest rate is fixed for 15 years then changes one time for the remaining term. Everyone we've talked to says these are ARM loans. However, in our loan platform all ARM programs must have a subsequent rate and payment change date. Is anyone else offering these products? If so, how are they disclosing?
If we offered a HELOC teaser rate in the past, does that APR need to be reflected in the Application Disclosure Historical Index Table? The Official Interpretation of 1026.40(d)(12)(x) 4. Amount of discount or premium. This uses the word "may."
If TILA disclosures are provided in a loan to a business entity and the APR is understated - is this a violation of regulation Z although loans to business entities are exempt from the coverage of Regulation Z?
Should non-RE loans that exceed the dollar threshold for Regulation Z coverage still be considered consumer loans as far as coding and reporting?
We have a difference of opinion. One side believes the Reg Z exemption essentially changes the loan into a commercial loan in every way. The other thinks that the disclosures in the documentation is where the exemption is primarily seen and the loan should be coded and reported exactly like any other loan of its type that is under the threshold. Any clarification would be appreciated.
Do we have to disclose the actual MAPR to all borrowers?
Can we report a past due loan to the credit bureau when SCRA protections apply?
We found an HPML in our audit. There is no escrow set up. What can we do?