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Latest Compliance - TILA Topics

Reg Z TILA Disclosures Requirements for Fixed Loan

06/03/2013

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?

Reg Z TIL Right of Rescission-Spec Home

08/20/2012

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.

Rules for Loan on a Principal Dwelling to a Trust

12/05/2011

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?

Borrower Using Another Person's Home as Collateral

08/22/2011

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?

Specifying Term on TILA

03/07/2011

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?

HUD-1 - Negative Interim Interest

07/12/2010

If there is a negative interim interest (credit) on the HUD-1, shouldn't that be included in the calculation of the finance charge to calculate the APR?

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CFPB Updates TRID Guides

On May 15, 2018, the Bureau published updates to both versions of the Small Entity Compliance Guides (versions 4.1 and 5.2) and Guides to Forms (versions 1.5 and 2.1) to support the implementation

TRID: Dueling Coverage of TILA and RESPA (4 Action Steps)

by Lucy Griffin

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Titling Accts. for Payable on Death Purpose

08/09/2020

We have a savings account that was opened March of 1993 titled hypothetically: Mary Smith and John Smith Trustees for Tim Smith. Does anyone ever remember titling accounts this way for payable on death purpose?

Beneficial Owner Certification

08/09/2020

Regarding a Beneficial Owner Certification: ABC, LLC (Borrower) is 100% owned by DEF, Inc. DEF, Inc. is 33.33% owned by 3 individuals. Would I need to list the individuals as having 25% or more ownership on the certification, even though they are not owners of ABC, LLC?

Monetary Instruments Log for Credit Union

08/09/2020

I am trying to create a monetary instruments log for our credit union. I have not been able to find a list of the required information needed on the log. Where can I find that information?

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