05/17/2010
Regarding temporary financing or a bridge loan, it looks like RESPA does not apply but what about TILA?
03/22/2010
A customer wants a loan to refinance his home and get money to improve it. The loan will be for six months, with interest only payments while the work is completed. At the expiration of six months, the loan will be modified to be a seven year balloon loan. At inception, isn't this loan HMDA reportable and HOEPA applicable?
03/22/2010
When is a bridge loan exempt from RESPA? I know the standard answer is "bridge or swing loans where a lender takes a security interest in property that would otherwise be covered are exempt". I'm looking for guidelines. Is there a max term? Does it have to be secured by both the property being purchased and the property they are trying to sell? I have a loan that is for twelve months and is secured only by the property being purchased. Would this be covered or exempt?
02/01/2010
Do we need to provide a TIL disclosure within three business days of receiving an application for a construction loan on applications received after July 30, 2009? Our construction loan term is twelve months or eighteen months. Are we allowed the temporary financing Reg Z exemption under the new MDIA ruling?
03/16/2009
Are all loans that are limited to a two-year term or less considered temporary financing and so RESPA disclosures would not be required?
02/09/2009
I know that open-end lines of credit are exempt from HMDA reporting, but what about closed-end lines of credit?
12/15/2008
We have a home construction loan with temporary financing that has now been refinanced by us into a mortgage. Is it reported as a purchase or refinance for HMDA?
11/24/2008
My studies indicate lines of credit are optionally reported (we do not report). Most of the writings seem to equate lines of credit with home equity lines of credit with no distinction between closed-end and open-end. Are there different reporting rules for open-end and closed-end lines of credit?
06/23/2008
I have paid off our customer's first mortgage and will be using all of the customer's remaining equity as a down payment on the purchase of their new primary residence. I set up the new loan as a single pay loan due in six months. The repayment on this loan will be the sale of the existing home. Is this considered a bridge loan and not HMDA reportable?
06/02/2008
I have been unable to find the definition of a bridge loan. Are we required to take both the old and new home as collateral in order to classify the loan as a bridge loan? Also, since the interpretation for temporary financing has changed to exclude the sale of assets would bridge loans now be HMDA reportable?