What are the last changes on RESPA and Reg Z ?
Is a new truth in-lending required when there is a change in circumstances? (2nd lien)
Are any TILA disclosures required when an open end HELOC has the option to fix portions of the line during the draw period? The fixed loan options are tied to the line and work like a credit card with fixed rate options.Where in Reg Z is this addressed?
Can we change the business address on the system from the owners home address to the address where the business is conducted without written authorization from the business owner?
We have a customer that is buying a spec home from a builder. The customer has moved into the spec home prior to the loan being closed. Does this loan require that we give a Right of Rescission to the borrower? Our compliance consultant company says NO but I have an employee at an IBA seminar today that is saying per Reg Z says No but Truth in Lending Law says Yes so we should do a rescission.
If part of line 801 "Origination Fee" is broken out as Doc Prep Fee, can that portion be excluded from the Finance Charge for TILA?
When you are doing a loan on a principal dwelling to a Trust (to purchase the dwelling to live in) would this be a consumer transaction and would they need to sign a TIL closing statement?
My borrower is using another person's home as collateral on her loan. The person putting up the collateral is not on the loan. Who signs the disclosures (good faith, tila, etc)? Is it the borrower or the person putting up the collateral or both?
Our new TILA does not have the term on it example: 5 payments at $350.00 with a balloon of $2000.00 Is this correct for a fixed rate decreasing with a balloon?
YSP was not considered APR impacting prior to RESPA Reform (built into the rate). With the change on the GFE to reflect YSP as a credit to the borrower, is this now APR impacting? We think is should be treated the same way it was prior to RESPA reform, but are concerned RESPAs change may have an unintended impact on Regulation Z.