Most Popular Compliance Content
RESPA - Title Company Broker Fee
01/12/2009
In the HUD settlement for a purchase of a 1-4 family dwelling for rental purposes, the title company included a broker fee in addition to the commissions earned by the real estate company as part of the settlement to be paid at closing by the buyer/borrower. Should we accept this as part of our settlement without proof that the fee was earned by the real estate agent? Assuming it is a legitimate fee, should this be disclosed as a finance charge for APR calculation?
CD Changes - Notice to Customers
01/12/2009
We are changing a feature in our CDs. How many days/months notice do we have to give our customers before we can actually delete a feature we will no longer offer?
HMDA - Double Reporting?
01/12/2009
If we have a balloon note coming due and we are going to extend the loan out, is it HMDA reportable? We are changing the loan number with no new money and we are not satisfying the mortgage. The original loan is within the same financial institution as the renewal. We reported it at origination of the original loan so if we report it again will it be double reporting?
HMDA - Repurchase of Loan
01/05/2009
If a company sells a loan to an investor and then repurchases the loan within the same HMDA year, does the sale to the investor have to be reflected on the LAR?
E-Statement Conversion - Signatures on File?
01/05/2009
We are going to start converting customers to an e-statement program. From what I can tell the only compliance issue is with the disclosure of e-statement viewing procedures and notification. When contacting our customers by phone we are verifying identity and signing them up for electronic statements. Do we need an actual signature on file?