When a loan moves from "interim servicing," to "servicing," is a short year statement required under RESPA? As an example, say a loan closed and was purchased by an investor 15 days later. The investor takes entire escrow balance with the deal, so would short year end escrow statement be required? In another example, if we as the original lender collect first payment and the investor leaves one month of mortgage insurance to pay from escrow balance, are we required to send a short year escrow statement to the borrower? Is there a specific regulations that clearly states interim servicing vs servicing?
Once a trustee dies what is the responsibility of the Successor Trustee. Can the successor trustee keep the funds in the same trust or do they need to get their own trust drawn up. The successor is also the beneficiary of the trust.
Is there a requirement on how many places after the decimal point to use when quoting rates on a rate sheet or advertisement? Two or three places?
If Bank receives a copy of a DL for a Beneficial Owner that has a different address than supplied on the collection form or the Bank is only provided a passport with no address, would we need to collect other documents to prove address and/or social? I feel like we would be criticized for only being able to verify two out of four pieces of identification.
As to identification of a beneficial owner on a legal entity account, are we required to actually "verify" the information they give us, or will them giving us a copy of their Driver's License and telling us their Social Security number be sufficient? Some beneficial owners may not necessarily be in the bank when the account is opened, and therefore cannot provide permission for us to run their information through Chexsystems or another similar consumer database. I know we will collect a copy of the identification and keep this on file for the recordkeeping requirements and we will also perform an OFAC check, but are we required to verify this information? And if we are, how will we accomplish this without a signature from them?